EXHIBIT F 

Case: 1:20-cv-03678 Document #: 50-6 Filed: 08/20/21 Page 1 of 4 PageID #:429
From: Robert Meloni

To: Darke, Richard P.

Cc: Thomas McCaffrey; Christopher M. Heintskill (cheintskill@lplegal.com)

Subject: RE: Heard v Trax

Date: Thursday, August 19, 2021 4:07:00 PM

Only 3 and 8 were include. 1,2, 4-7 were not produced.

These are listed in my Rule 37 Letter:

1. Trax Music Catalogue. (TPC, ⁋5);

2. Demon License Agreement. (Id. ⁋6);

3. 2012 Settlement Agreement (Id., ⁋8): attached to Third Party Complaint, Ex. 2

4. 2002 Joint Venture Agreement (Id., ⁋16);

5. 2004 Amendment to Joint Venture Agreement (Id.);

6. 2005 Judgment (Id., ⁋17);

7. 2006 Purchase of Master Recordings and Trax Music Catalogue under the UCC (Id.,

⁋18); and

8. 2007 Casablanca/Demon Music Group License Agreement (Id. ⁋19): attached to

Third Party Complaint, Ex. 1

-Robert S. Meloni 

Meloni & McCaffrey

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New York, New York 10019

(t) (212) 520-6090

(m) (917) 331-9556

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(e) rmeloni@m2lawgroup.com

(w) http://m2lawgroup.com

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From: Darke, Richard P. <RPDarke@duanemorris.com> 

Sent: Thursday, August 19, 2021 3:28 PM

To: Robert Meloni <rmeloni@m2lawgroup.com>

Case: 1:20-cv-03678 Document #: 50-6 Filed: 08/20/21 Page 2 of 4 PageID #:430
Cc: Thomas McCaffrey <tmccaffrey@m2lawgroup.com>; Christopher M. Heintskill

(cheintskill@lplegal.com) <cheintskill@lplegal.com>

Subject: RE: Heard v Trax

Robert,

Thanks for the email.

Re the document you are looking for, did you review the exhibits that were attached to the thirdparty complaint that was filed against Casablanca? Start there, and let me know if you need

additional documents.

We will have dates for you tomorrow.

Thanks,

Rick

From: Robert Meloni <rmeloni@m2lawgroup.com> 

Sent: Thursday, August 19, 2021 2:12 PM

To: Darke, Richard P. <RPDarke@duanemorris.com>

Cc: Thomas McCaffrey <tmccaffrey@m2lawgroup.com>; Christopher M. Heintskill

(cheintskill@lplegal.com) <cheintskill@lplegal.com>

Subject: Heard v Trax

Richard:

August 20 Deadline:

We must file a joint status report tomorrow with the names of all remaining deponents and

confirmed dates for their depositions through the end of fact discovery. Do you have a

list for me?

We need to select dates for each by tomorrow.

Also, my primary issue with your document production is that documents which your

pleading has placed in issue were not produced. More specific issues with that

production are outlined in the attached letter sent pursuant to Rule 37. If the issue that

your client no longer possesses those documents, then please say so in each instance

outlined in the attached letter, explaining why they are no longer available.

Let me know when you can speak.

-Robert S. Meloni 

Case: 1:20-cv-03678 Document #: 50-6 Filed: 08/20/21 Page 3 of 4 PageID #:431
Meloni & McCaffrey

3 Columbus Circle |15th Floor 

New York, New York 10019

(t) (212) 520-6090

(m) (917) 331-9556

(f) (917) 210-3758

(e) rmeloni@m2lawgroup.com

(w) http://m2lawgroup.com

NOTICE: The information in this Internet e-mail, which includes this e-mail message and any attachments, is attorney client privileged

and/or confidential information. The information contained in this message is intended only for the use of the individual or entity

named above. Access to this Internet e-mail by anyone else is unauthorized. If the reader of this message is not the intended recipient,

or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination,

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immediately notify us by telephone or by e-mail and delete this e-mail from your system. Receipt by anyone other than the intended

recipient is not a waiver of any attorney/client privilege or work product privilege.

For more information about Duane Morris, please visit http://www.DuaneMorris.com

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Case: 1:20-cv-03678 Document #: 50-6 Filed: 08/20/21 Page 4 of 4 PageID #:432