· EXHIBIT G 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 1 of 11
From: Chase Turrentine 

To: Joshua Wurtzel; Tyler Swensen; Victoria Stevens 

Cc: 

Subject: 

Dennis Wileochik; fil!oJ.iD.; Jeffrey M. Eilender; Bradley J. Nash; htaylor@rrulaw.com 

RE: Responses to RFPs and Interrogatories 

Date: Thursday, April 18, 2019 8:59:52 PM 

Attachments: imaqe001.pnq 

imaqe002.pnq 

imaqe442833.ona 

Hi Josh, 

Sorry for the delay. We have the following regarding your questions: 

The last known business address for Dennis Danzik, according to Hinz is: 7543 E Tierra Buena Ln., Scottsdale, AZ 85260. Mr. Hinz 

does not know what his home address is. 

Also, I confirmed that both Elizabeth (part-time) and Jovahna are still employed and we should have no problem producing them. 

Let me know. Thanks 

www.wb-law.com 

Chase Turrentine 

Attorney at Law 

The V\11Ienchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The infonnation transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged material. Any 

interception, review, retransmission, dissemination or other use of this infonnation by persons or entities other than the intended recipient is prohibited 

by law and may subject them to criminal or civil liability. If you received this communication in error, please contact us immediately at (602) 606-

2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Thursday, April 18, 2019 6:49 AM 

To: Chase Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; admin <admin@wb-law.com>; Jeffrey M. Eilender <jeilender@schlamstone.com>; 

Bradley J.Nash<bnash@schlamstone.com>; htaylor@rrulaw.com 

Subject: RE: Responses to RFPs and Interrogatories 

Following up on the third and fourth bullet points below, which you said you would promptly get back to me on. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 2 of 11
From: Joshua Wurtzel 

Sent: Monday, April 15, 2019 1:25 PM 

To: Chase Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; ad min <admin@wb-law.com>; Jeffrey M. Eilender <ieilender@schlamstone.com>; 

Bradley J. Nash <bnash@schlamstone.com>; htaylor@rrulaw.com 

Subject: FW: Responses to RFPs and Interrogatories 

As a follow up to today's call, see below in red. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

iwurtzel@schlamstone.com 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Chase Turrentine <chaset@wb-law.com> 

Sent: Monday, April 15, 2019 12:15 PM 

To: Joshua Wurtzel <iwurtzel@schlamstone.com>; Heather Zwick <heatherz@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; htaylo1·@rrulaw com; Jeffrey M. Eilender 

<ieilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Hilary Myers <HilaryM@wb-lav'Lffiill.>; Wyo Tech adv 

Wei Is Fargo (es 7659d03+matterl 136246401@ma i Id rop.clio. com) <0 7659d03+matterl 13624640l@ma i Id rop .cl io. com> 

Subject: RE: Responses to RFPs and Interrogatories 

Hi Josh, 

Since the call already got pushed back a few minutes, can we touch base at 9:30 AZ time (12:30 NY time)? We'll be able to address 

these issues on the call then. 

www .wb-law.com 

Chase Turrentine 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY /CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged material. Any 

interception, review, retransmission, dissemination or other use of this information by persons or entities other than the intended recipient is prohibited 

by law and may subject them to criminal or civil liability. If you received this communication in error, please contact us immediately at (602) 606-

2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Friday, April 12, 2019 5:18 PM 

To: Heather Zwick <heatherz@wb-law.com> 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 3 of 11
Cc: Dennis Wilenchik <diw@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey M. Eilender 

<jeilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.sm>; Chase Turrentine <chaset@wb-law.com>; Hilary 

Myers <HilaryM@wb-law.com>; Wyo Tech adv Wells Fargo (e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matterl 136246401@maildrnp.clio com> 

Subject: RE: Responses to RFPs and Interrogatories 

Dennis, 

Please be prepared to address the following on our call on Monday: 

• Discovery deadline extension. I asked you for an extension until October 29, given that we still have not gotten Wyo Tech's 

responses to our document demands and interrogatories, let alone non party productions or depositions. Please let me 

know if you consent to this extension. Wyo Tech consents to extend the fact-discovery deadline to October 29, 2019. I will 

circulate a draft stipulation and proposed form of order setting out the good cause. In the proposed order, I will back up all 

the deadlines that follow the fact-discovery deadline accordingly. 

• Wyo Tech's document production and interrogatory responses. We served these on February 3, and Wyo Tech's 

responses were due on March 4. You then requested an extension to April 1-to which we agreed-and then requested 

another extension to April 5-to which we again agreed. But it is now April 12, and we haven't received any documents or 

even written responses. Given the court's April 9 order, and given that it has now been over two months since we served 

these, Wyo Tech should be able to make a substantial production and respond substantively to our interrogatories 

immediately. Please confirm that Wyo Tech will make a substantial production and respond substantively to our 

interrogatories in the next few days; if you cannot confirm this, we will seek relief from the court. Wyo Tech will serve 

written responses to the document requests and interrogatories by April 22, along with a substantial production. The CWT 

Parties agree to enter into a confidentiality order; you will send me a draft to review. 

• Party depositions of Wyo Tech, Bill Hinz, Jovahna Danzik, and Elizabeth Danzik. David said that Wyo Tech will produce 

these witnesses in accordance with the Rule 34 notices we served on February 3. We noticed these depositions for dates in 

March, but because Wyo Tech had not produced any documents in response to our RFPs and had not responded to our 

interrogatories, we were forced to adjourn these depositions. Please be prepared to discuss dates for each of these 

witnesses, which can be scheduled only when we know when Wyo Tech will make a complete production and respond to 

our interrogatories. Though Timchak previously represented, by February 21, 2019 e-mail, that Wyo Tech would produce 

Bill Hinz, Jovahna Danzik, and Elizabeth Danzik in accordance with the Rule 34 deposition notices, you are not sure whether 

this remains Wyo Tech's position and will confirm and let me know in the next day or two. We reserve our right to argue 

that any objections to the deposition notices have been waived. 

• Service of a subpoena on Dennis Danzik, .As you know, Wyo Tech initially disclosed Mr. Danzik as a person with relevant 

knowledge, and listed his contact information as c/o your firm. But on February 3, when we served a Rule 34 deposition 

notice on your firm seeking Mr. Danzik's deposition, you claimed that a deposition notice was improper because Mr. Danzik 

no longer works for Wyo Tech, and further refused to accept service of a subpoena on him. We then asked you to give us 

his address and demanded that Wyo Tech update its MIDP responses. But you claimed that don't have Mr. Danzik's 

address, and Wyo Tech amended its MIDP responses to state that it is "currently unaware of Dennis Danzik's physical 

residential address." Though disingenuous, I followed up and asked whether Wyo Tech knows Mr. Danzik's current business 

address, on which David said he would check but never got back to me. Despite Wyo Tech's claim in its amended MIDP 

response, we know that Mr. Hinz-Wyo Tech's CEO-regularly works with Mr. Danzik through Inductance and other shell 

companies set up for the purpose of "employing" Mr. Danzik. Thus, if Mr. Hinz does not know where Mr. Danzik lives or 

works, he certainly could find out. We thus demand that he do so, and that you provide us with Mr. Danzik's current home 

and business addresses on Monday's call. If you refuse, we will seek relief from the court. You will check with Bill Hinz to see 

if he knows Dennis Danzik's business and home addresses and, if so, provide them. 

• Nonparties' noncompliance with subpoenas. As you know, in early February, we served approximately a dozen subpoenas 

on nonparties to this action, including various Danzik-related entities and people we believe are Wyo Tech investors. But 

none of these nonparties responded to our subpoenas. In your February 28 letter to me, you said that "Wyo Tech has 

commanded that the investors do not comply" with the subpoenas we served. Given the court's April 9 order, please 

confirm that you will contact all non parties we have served in this case that you previously "commanded" not to comply 

with our subpoenas and withdraw this "command[]"-and further encourage the nonparties to comply. If you refuse to 

confirm, we will seek relief from Judge Lanza, and will also begin enforcement actions against these witnesses in other 

jurisdictions as necessary. You agreed not to interfere with the subpoena recipients' responses. I said we would deal directly 

with the subpoena recipients and reserve all rights against them and Wyo Tech if it interferes with their responses. 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 4 of 11
I look forward to our meet and confer on Monday. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwu rtzel@schlamstone.com 

CommercialDivisionBlo[UQ[)J. 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Joshua Wurtzel 

Sent: Wednesday, April 10, 2019 2:39 PM 

To: Heather Zwick <heatherz@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey M. Eilender 

<jeilende1·@schlamstone.corn>; Bradley J.Nash<bnash@schlamstone.com>; Chase Turrentine <chaset@wb-law.com>; Hilary 

Myers <HilaryM@wb-law.c.om>; Wyo Tech adv Wells Fargo (e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matter113624640J.@maildrop.clio com> 

Subject: Re: Responses to RFPs and Interrogatories 

Great confirmed. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York NY 10004 

Tel.: (212) 344-5400 (x 32'1) 

iwu1tiel.@schlamstone.com 

CommercialDivisionBlog.com 

On Apr 10, 2019, at 2:26 PM, Heather Zwick <heatherz@wb-law.com> wrote: 

9 am AZ time on Monday works. 

www.wb-law.com 

Heather Zwick 

Executive Assistant 

The Wilenchik & Bartness Building 

281 o North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged material. 

Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the intended 

recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, please 

contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 5 of 11
From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Wednesday, April 10, 2019 11:24 AM 

To: Heather Zwick <heatherz@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey 

M. Eilender <jeilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Chase Turrentine 

<chaset@wb-law.com>; Hilary Myers <HilaryM@wb-law.com>; Wyo Tech adv Wells Fargo 

(eS 7659d03+matterl 136246401@mai Id rop. clio.com) <eS 7659d03+matterl 136246401@mai!drop.cl io com> 

Subject: Re: Responses to RFPs and Interrogatories 

No, but I can do 8:30 or 9 am AZ time. Does that work? 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York NY 10004 

Tel.: (212) 344-5400 (x 324.). 

jwurtzel@schlamstone.com 

Comm erci a I Division BI O!U.Qill 

On Apr 10, 2019, at 2:23 PM, Heather Zwick <heatherz@wb-law.com> wrote: 

Hi Joshua, could you do the phone call earlier at 10:30 AZ time on Monday instead? 

www.wb-law com 

Heather Zwick 

Executive Assistant 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY /CLIENT COMMUNICATION 

The infonnation transmitted by this e-mail is intended only for the addressee and may contain confidential and/or 

privileged material. Any interception, review, retransmission, dissemination or other use of this infonnation by persons 

or entities other than the intended recipient is prohibited by law and may subject them to criminal or civil liability. If you 

received this communication in error, please contact us immediately at (602) 606-2810, and delete the communication 

from any computer or network system. 

From: Dennis Wilenchik <.d.iw@wb-law.com> 

Sent: Wednesday, April 10, 2019 11:20 AM 

To: Joshua Wurtzel <jwurtzel@schlamstollidQID> 

Cc: Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey M. Eillnder 

<jeilender@schlamstone.com>; Bradley J.Nash<bnash@schlamstone.com>; Chase Turrentine 

<chaset@wb-law.com>; Hilary Myers <HilaryM@wb-law.com>; Wyo Tech adv Wells Fargo 

(~7659d03+matterl 136246401@mai ldrop.clio. com) 

<~7659d03+matterl 136246401@ma i Id rop.clio.com>; Heather Zwick <heatherz@wb-law.com> 

Subject: RE: Responses to RFPs and Interrogatories 

Thanks. Heather pis set something up. 

Sincerely Yours, 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 6 of 11
Dennis Wilenchik 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY /CLIENT COMMUNICATION 

The infonnation transmitted by this e-mail is intended only for the addressee and may contain confidential and/or 

privileged material. Any interception, review, retransmission, dissemination or other use of this infonnation by persons 

or entities other than the intended recipient is prohibited by law and may subject them to criminal or civil liability. If you 

received this communication in error, please contact us immediately at (602) 606-2810, and delete the communication 

from any computer or network system. 

From: Joshua Wurtzel [mailto:iwurtzel@schlamstone.com] 

Sent: Wednesday, April 10, 2019 11:19 AM 

To: Dennis Wilenchik <diw@wb-law.com> 

Cc: Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey M. Eilender 

<ieilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Chase Turrentine 

<chaset@wb-law.com>; Hilary Myers <HilaryM@wb-law.com>; Wyo Tech adv Wells Fargo 

( es 7659d03+matterl 136246401@mai Id rop. cl io.com) 

<eS 7659d03+matterl 136246401@ma i Id rop .cl io.com> 

Subject: Re: Responses to RFPs and Interrogatories 

Welcome back. 

How about 11:30 am your time/2:30 pm EST on Monday? 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York NY 10004 

Tel.: (212) 344-5400 (x 324) 

iwu rtzel@sch la mstone.com 

Commercial Division Blog.com 

On Apr 10, 2019, at 2:16 PM, Dennis Wilenchik <diw@wb-law.com> wrote: 

We are not ignoring anything. I just got back today and met with my folks who are 

gathering together information. I suggest we get a phone call set up next week to go over 

a bunch of things. thanks 

Sincerely Yours, 

www.wb-law.com 

Dennis Wilenchik 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 7 of 11
ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or 

privileged material. Any interception, review, retransmission, dissemination or other use of this information by persons 

or entities other than the intended recipient is prohibited by law and may subject them to criminal or civil liability. If you 

received this communication in error, please contact us immediately at ( 602) 606-2810, and delete the communication 

from any computer or network system. 

From: Joshua Wurtzel [mailto:jwurtzel@schlamstone.com] 

Sent: Wednesday, April 10, 2019 11:12 AM 

To: Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey M. Eilender 

<ieilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com> 

Cc: Chase Turrentine <chaset@wb-law.com>; Hilary Myers <HilaryM@wb-law.com>; Wyo 

Tech adv Wells Fargo (eS 7659d03+matter1l3624640l@maildrop.clio.com) 

<e57659d03+matter113624640l@maildrop.clio.com>; Dennis Wilenchik <diw@wblaw.com> 

Subject: Re: Responses to RFPs and Interrogatories 

I am following up on the schedule and your production. You promised it by April 5. It is 

now April 10. When will we get it? If you keep ignoring these we requests, we will just 

move to compel. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

Commercial Division Blog.com 

On Apr 8, 2019, at 10:33 PM, Joshua Wurtzel <jwurtzel@schJ.il.m.s!one.com> wrote: 

Counsel, 

Where is Wyo Tech's document production and interrogatory responses? 

Given the Court's statement today that discovery will go forward, we will 

renotice all the depositions and enforce all subpoenas against all nonparties 

we served. Please let me know if you will consent to the proposed extension 

below 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

<image00l.png> 

Commercial Division Blog.com 

This e-mail, including al I attachments, is for the use of the intended recipients 

only. It may contain legally privileged or confidential information. If you are 

not the intended recipient, please permanently delete this message and all 

copies or printouts, and please notify me immediately. 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 8 of 11
From: Joshua Wurtzel 

Sent: Sunday, March 31, 2019 9:03 AM 

To: Victoria Stevens <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey 

M. Eilender <ieilender@schlamstone.com>; Bradley J. Nash 

<bnash@schlamstone.com> 

Cc: Chase Turrentine <chaset@wb-law.com>; Hilary Myers <HilaryM@wb-

~>; Wyo Tech adv Wells Fargo 

(eS 7659d03+matterl 136246401@ma i Id rop.clio.com) 

<e57659d03+matterll3624640l@maildrop.clio.com>; Dennis Wilenchik 

<diw@wb-law.com> 

Subject: RE: Responses to RFPs and Interrogatories 

Counsel, 

As you know, we agreed to extend Wyo Tech's time to respond to our RFPs 

and interrogatories to April 1 (and now April 5), and we also agreed to 

adjourn the party depositions we noticed until after we get Wyo Tech's 

document production and interrogatory responses and adjourn the nonparty 

depositions we scheduled after the nonparties comply with the subpoenas 

we served (to date, they have not). 

As you also know, under the current schedule, the deadline to complete fact 

discovery is April 29. But we are not getting Wyo Tech's responses to our 

initial discovery demands until April 1, your motion to quash (which, as the 

Court observes, implicates several other discovery-related issues in this case) 

is still pending, and none of the non parties we subpoenaed responded to our 

subpoenas-and we will thus need to seek orders compelling them to comply 

in multiple jurisdictions-the April 1 deadline must be extended. Further, we 

also plan to seek an order authorizing alternative service on Dennis Danzik, 

and critically, as you know, we just filed a motion in the Wyoming bankruptcy 

court to allow this case to go forward given Danzik's recent Chapter 7 filing. 

Thus, the April 29 fact discovery deadline must be extended. 

Given the significant amount of party and non party discovery that remains 

outstanding in this case, we propose extending the fact discovery deadline to 

October 29, with all other deadlines in the case similarly getting pushed back 

six months. Please let me know if you agree to this extension, and we can 

prepare a stip-in which we can include that your agreement to this schedule 

is without prejudice to your right to argue that it should be further amended 

if the court rules that we are not entitled to discovery in this case. But we 

cannot wait until after the court rules on the motion to quash to seek this 

extension, since the court may not rule for several weeks and the deadline is 

fast approaching. 

Thanks. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

iwurtzel@schlamstone.com 

~ 

Commercial Division Blog.com 

This e-mail, including all attachments, is for the use of the intended recipients 

only. It may contain legally privileged or confidential information. If you are 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 9 of 11
not the intended recipient, please permanently delete this message and all 

copies or printouts, and please notify me immediately. 

From: Joshua Wurtzel 

Sent: Friday, March 29, 2019 7:19 PM 

To: 'Victoria Stevens' <VictoriaS@wb-law.com>; htaylor@rrulaw.com; Jeffrey 

M. Eilender <jeilender@schlamstone.com>; Bradley J. Nash 

<bnash@schlamstone com> 

Cc: Chase Turrentine <chaset@wb-law.com>; Hilary Myers <HilaryM@wblaw.com>; Wyo Tech adv Wells Fargo 

( e57659d03+matterl 136246401@mai Id rop. cl io.com) 

<eS 7659d03+matterl 136246401@ma i Id rop.clio.com> 

Subject: RE: Responses to RFPs and Interrogatories 

That is fine. 

Joshua Wurtzel 

Sch lam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone com 

<imageO0l.png> 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients 

only. It may contain legally privileged or confidential information. If you are 

not the intended recipient, please permanently delete this message and all 

copies or printouts, and please notify me immediately. 

From: Victoria Stevens <VictoriaS@wb-law.com> 

Sent: Friday, March 29, 2019 7:13 PM 

To: htaylor@rrulaw.com; Jeffrey M. Eilender <jeilender@schlamstone.com>; 

Joshua Wurtzel <jwurtzel@schlamstone.com>; Bradley J. Nash 

<bnash@sch!umstone con1> 

Cc: Chase Turrentine <chaset@wb-law.com>; Hilary Myers <HilaryM@wb-

~>; Wyo Tech adv Wells Fargo 

(.e.5 7659d03+ matterl 136246401@mai Id rop. clio. com) 

<e57659d03+matterl 136246401@maildrop clio corn> 

Subject: Responses to RFPs and Interrogatories 

Importance: High 

Mr. Taylor: 

Thank you for discussing the deadline for the Responses to the 

Requests for Production of Documents and the Interrogatories, sent on or 

about February 3, 2019 to David Timchak. As you know, David has left the 

firm and Chase R. Turrentine has taken over this case. The deadline to 

respond to the RFPs and Interrogatories is April 1, 2019, based upon an email 

agreement. As I explained, we need additional time. We request an 

extension to respond to these to April 5, 2019. 

If you have any questions, please do not hesitate to contact Chase 

directly. If he is not available, contact me and I will do what I can to assist. 

We appreciate the professional courtesy. 

Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 10 of 11
www wb-::law.com 

Victoria Stevens 

Senior Paralegal 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The infonnation transmitted by this e-mail is intended only for the addressee and may contain confidential and/or 

privileged material. Any interception, review, retransmission, dissemination or other use of this information by persons 

or entities other than the intended recipient is prohibited by law and may subject them to criminal or civil liability. If you 

received this communication in error, please contact us immediately at ( 602) 606-2810, and delete the communication 

from any computer or network system. 

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Case 2:17-cv-04140-DWL Document 174-7 Filed 07/08/19 Page 11 of 11