Exhibit M

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 1 of 6
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

April 16, 2019

BY OVERNIGHT FEDEX

Danzik Applied Sciences, LLC

c/o Resident Agents Inc.

8 The Green, Suite R

Dover, Delaware 19901

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

To Whom It May Concern:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 4, 2019, we served Danzik Applied Sciences, LLC 

(“DAS”) with the attached subpoenas in this action, which seek DAS’s production of 

documents and attendance at a deposition. DAS’s document production was due on February 

28, 2019, but we have not received any response to the subpoena from it.

Please either produce the documents requested by the subpoena, or reach out to me to discuss 

DAS’s production and deposition, by April 19, 2019. Once we get your document production, 

we can schedule a mutually-convenient date for DAS’s deposition in accordance with Fed. R. 

Civ. P. 30(b)(6). If we do not hear from DAS by April 19, we will seek a court order 

compelling DAS’s compliance with the subpoena—and reserve our right to seek recovery of 

our attorneys’ fees incurred in doing so.

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 2 of 6
Danzik Applied Sciences, LLC

April 16, 2019

Page 2 of 2

We look forward to DAS’s document production and testimony.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 3 of 6
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

April 16, 2019

BY OVERNIGHT FEDEX

Messrs. Charles J. Davis and Richard W. Davis

2552 East Los Alamos Street

Gilbert, Arizona 85295

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Messrs. Davis:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 4, 2019, we served you with the attached subpoena in this 

action, which seeks your production of documents. Your document production was due on 

February 28, 2019, but we have not received any response to the subpoena from you.

Please either produce the documents requested by the subpoena, or reach out to me to discuss 

your production, by April 19, 2019. If we do not hear from you by April 19, we will seek a

court order compelling your compliance with the subpoena—and reserve our right to seek 

recovery of our attorneys’ fees incurred in doing so.

We look forward to your document production and testimony.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 4 of 6
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

April 16, 2019

BY OVERNIGHT FEDEX

Mr. Ali M. Mosharrafa 

Ms. Kristin Joiner Mosharrafa

5346 East Royal Palm Road

Paradise Valley, Arizona 85253

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. and Ms. Mosharrafa:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 11, 2019, we served you with the attached subpoena in 

this action, which seeks your production of documents. Your document production was due 

on March 18, 2019, but we have not received any response to the subpoena from you. 

Please either produce the documents requested by the subpoena, or reach out to me to discuss 

your production, by April 19, 2019. If we do not hear from you by April 19, we will seek a 

court order compelling your compliance with the subpoena—and reserve our right to seek 

recovery of our attorneys’ fees incurred in doing so.

We look forward to your document production and testimony.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 5 of 6
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

April 16, 2019

BY OVERNIGHT FEDEX

Mr. Tamir Mosharrafa 

Ms. Ashley Mosharrafa

11206 North Saint Andrews Way

Scottsdale, Arizona 85254

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. and Ms. Mosharrafa:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 11, 2019, we served you with the attached subpoena in 

this action, which seeks your production of documents. Your document production was due 

on March 18, 2019, but we have not received any response to the subpoena from you. 

Please either produce the documents requested by the subpoena, or reach out to me to discuss 

your production, by April 19, 2019. If we do not hear from you by April 19, we will seek a 

court order compelling your compliance with the subpoena—and reserve our right to seek 

recovery of our attorneys’ fees incurred in doing so.

We look forward to your document production and testimony.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 169-1 Filed 07/01/19 Page 6 of 6