Hill"
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------X
J-BAR REINFORCEMENT INC., Index No. 650404/2016
(Scarpulla, J.S.C.)
Plaintiff,
AFFIRMATION IN SUPPORT-v- OF DEFENDANTS' SECOND
MOTIONS TO DISQUALIFYCREST HILL CAPITAL LLC, PLAINTIFF'S COUNSEL
Defendant. Mot. Seq. 008
---------------------------------X
J-BAR REINFORCEMENT INC.,Index No. 650294/2017
Plaintiff,(Scarpulla, J.S.C.)
Mot. Seq. 003
MANTIS FUNDING LLC,
Defendant.
______--_--_----...--------------------X
JACOB H. NEMON, an attorney duly admitted to practice law before the Courts of the
State of New York, affirms the following to be true and correct, under the penalty of perjury:
1. I am an Associate with Carter Ledyard & Milburn LLP, attorneys for Crest Hill
Capital LLC ("Crest("
Hill") and Mantis Funding LLC ("Mantis"and together, the "Companies"),
"Companies"
the defendants in the above-captioned related matters.
2. I respectfully submit this Affirmation in theCompanies'
second set of identical
motions to disqualify Plaintiff J-Bar Reinforcement, Inc.'s counsel, Raymond Markovich, Esq.
("("Mr. Markovich") and his purported law firm that uses the "U.S. Law Group"
trade name, for
violating the applicable regulations and failing to satisfy the requirements to practice law in
New York State.
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L Relevant Procedural History
3. The Law Offices of David J. Shapiro P.C. filed the Crest Hill Aaction on January
26 2016, and subsequently filed the related action against defendant Crest Hill's corporate
affiliate, Mantis, on January 18, 2017. That firm actively represented Plaintiff in these actions at
least through April 19, 2017. See Mantis Dkt. No. 23. Notably, these actions were commenced
as motions for summary judgment in lieu of complaint, and the summary judgment motions were
fully briefed and argued while that firm represented Plaintiff J-Bar.
4. In May 2017, Mr. Markovich filed Notices of Appearance on behalf of U.S. Law
Group, listing as the address for service his California address at 427 North Canon Drive, Suite
206, Beverly Hills, California 90210. Crest Hill Dkt. No. 66; Mantis Dkt. No. 24; true and
correct copies of the Notices of Appearance are annexed as Exh. A.
5. The Notices of Appearance did not state that Mr. Markovich was substituting as
counsel of record for The Law Offices of David J. Shapiro P.C. See id. In correspondence in
May and June 2017, Mr. Markovich did not dispute that The Law Offices of David J. Shapiro
P.C. remained as co-counsel. In a letter dated May 15, 2017, I wrote to Mr. Markovich as
follows:
I [ ] see that The Law Offices of David J. Shapiro P.C. remains as counsel for J-
Bar Reinforcement, Inc. ("J-Bar") in both the 2017 Action and the 2016 Action. I
am copying Mr. Shapiro on this correspondence. Please confirm that we should
be addressing correspondence to both you and The Law Offices of David J.
Shapiro P.C. as counsel for J-Bar in connection with both actions.
A true and correct copy of my May 15, 2017 letter to Mr. Markovich is annexed Exh. B. On
June 16, 2017, I began a letter to Mr. Markovich with "[w]e acknowledge your appearance as co-
counsel for J-Bar Reinforcement, Inc. [ ] in the above-referencedmatters." A true and correct
copy of my June 16, 2017 letter to Mr. Markovich is annexed as Exh. C.
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6. Mr. Markovich never denied that The Law Offices of David J. Shapiro P.C.
continued acting as his co-counsel, and even copied "David J. Shapiro,Esq."
on his response to
my letter on June 21, 2017. A true and correct copy of Mr. Markovich's June 21, 2017 letter to
me is annexed as Exh. D.
7. This apparent co-counsel relationship continued up to December 14, 2017. On
that date, apparently in response to an argument made by the Companies that Plaintiff J-Bar
would not be prejudiced by Mr. Markovich's disqualification in this action because The Law
Office of David J. Shapiro P.C. remained as counsel of record - Mr. Markovich filed Consents to
Change Counsel removing The Law Office of David J. Shapiro P.C. as counsel of record. Crest
Hill Dkt. No. 118; Mantis Dkt. No. 30; true and correct copies of the Consents to Change
Counsel are annexed as Exh. E. The Court should note that the substitutions of counsel do not
bear the actual signature of The Law Office of David J. Shapiro P.C. and were filed by Mr.
Markovich. See id.
IL U.S. Law Group Does Not Have a Partner or Any Attorney Based in Its
Purported New York Office
8. The attorney profiles on U.S. Law Group's webpage indicates that there are only
three attorneys of the firm that are admitted to practice law in New York. A printout of the
firm's main"Attorneys"
webpage is annexed as Exh. F. The firm's "attorney and founder",
Usman Sheikh, Esq., and Mr. Markovich and John Buckman, Esq., both of whom are listed as
"ofcounsel" - i.e., not partners - of the U.S. Law Group. Id. As set forth below, each maintain
their offices in either California and New Jersey.
9. Mr. Sheikh is a resident of Los Angeles, not New York, as set forth in a
November 19, 2017 interview of Mr. Sheikh in Naluda Magazine, that Mr. Sheikh posted on
3
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LinkedIn on December 5, 2017, a printout of which is annexed as Exh. G. In that interview, Mr.
Sheikh discusses his work in Hollywood and describes "the impetus for [his] move toLA"
from
New York to "work at a Top 4 talent agency to get a better understanding of showbusiness."
Id.
10. Mr. Markovich is a resident of California who transacts business primarily in
California.1Indeed, Mr. Markovich has exclusively used U.S. Law Group's California address
for service of papers in these actions (see Exh. A) as well as in his signature block on recent
filings, which he has signed in West Hollywood, California. See,e.g., Dkt. Nos. 68 (notice of
motion signed September 28, 2017), 98 (memorandum of law signed November 6, 2017).
11. Mr. Buckman's profile on the U.S. Law Group website claims that he "heads U.S.
Laws aw Group'sulvuP v NewLwvw Yorki via office", yet admits thatwzaa heia practices corporate law, not litigation.iawgawvii. A
printout of Mr. Buckman's profile (available at http://www.uslawgroupinc.com/attorney-john- -'ohn--'ohn-
buckman/), is annexed as Exh. H. However, in addition to not being an actual partner of U.S.
Law Group, it does not appear that Mr. Buckman even sits in U.S. Law Group's "virtual office"
at 30 Wall Street,8*
Floor, New York, New York 10005.
12. First, Mr. Buckman lists his address with the Offices of Court Administration
("OCA") as being in New Jersey, not New York, as follows: "JOHN BURR BUCKMAN IV,
BUCKMAN GROUP - CORPORATE COUNSEL LLC 11 S PASSAIC AVE FL 2,
CHATHAM, NJ07928-2379." A printout from the OCA webpage for Mr. Buckman is annexed
as Exh. I. Furthermore, Mr. Buckman's New York registration status is currently listed as
"Delinquent."Id.
' I believe that Mr. Markovich is a California resident based upon conversations in which Mr. Markovich indicatedthat he lived in Califomia and would need to fly in to New York for Court appearances, as well as Mr. Markovich'suse of U.S. Law Group's California address on his filings.
4
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..13. Second, Mr. Buckman maintains his'
own law firm's''
webpage, http://buckman-
group.com/,.corn/, which lists his firm address as being in New Jersey, not New York: "Buckman
Group- Corporate Counsel LLC, 11 S. Passaic Avenue, 2nd Floor, Chatham, NJ
07928." A
printout of Mr. Buckman's webpage is annexed as Exh. J.
14. Third, Mr. Buckman's LinkedIn profile indicates that in addition to his own law
firm, he is presently affiliated as an officer, director or general counsel of 10 companies. A
printout from Mr. Buckman's LinkedIn pages (available at .
https://www.linkedin.com/in/buckmanjohn/) is annexed as Exh. K.
HL U.S. Law Group Does Not Maintain a Bona Fide New York Office
15.l 4 U.S.V ~V LawLr4YV Group'sALV4JJ 3 website indicatesLllVlV4LVV thatVl41 itll maintains offices inLjj California&4lllVI lll4 at 427TC I
North Canon Drive, Suite 206, Beverly Hills, California 90210, and claims that it maintains a
"New YorkOffice"
at 30 Wall Street,8*
Floor, New York, New York 10005. A printout of the
firm's homepage is annexed as Exh. L. However, it is apparent that U.S. Law Group and Mr.
Markovich do not maintain a bona fide New York law office, but instead have, at most, only a
"virtualoffice."office."office."
16. A Google search reveals that numerous companies maintain webpages advertising
the availability of virtualoffice"
space at 30 Wall Street,8*8 Floor. These are not permanent
office spaces. For example, a webpage called Liquid Space describes the space as follows:
We are a Virtual Office Business Center that has been serving start-ups and
emerging companies, small and home based businesses and self-employed
professionals since 1986. We provide world-class business support services, at a
prestigious location where you can rent a conference room for an hour, half day or
a full day.
A printout of the Liquid Space listing (available at https://liquidspace.com/us/ny/new-york/your-
wall-street-office) is annexed as Exh. M.
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17. Another advertisement from "Opus Virtual Offices"describes the space offered at
30 Wall Street,80'
Floor, as "a virtual office in one of New York most prestigious business
addresses for a fraction of thecost"
for the purpose of making it "easy to open a business in New
York or in more cities or statessimultaneously,"
and to "project a corporate-like business
presence on a localbudget."
18. A printout of the Opus Virtual Offices listing (available at
https://www.opusvirtualoffices.com/virtual-office/new-york/new-york/location-972) is annexed
as Exh. N. Additionally, Offices.net writes about 30 Wall Street,89'
Floor, that:
This center provides your company with a prestigious Wall Street address, all
within a modern, beautifully appointed corporate setting including a fullyattended reception area. Virtual offices are also available starting from $75 per
month.
A printout of the Offices.net listing (available at https://offices.net/ny/new-york-city/36867/) is
annexed as Exh. O.
19. Notably, on at least one occasion during this litigation, mail sent to the New York
virtual office of U.S. Law Group was not received by Mr. Markovich. On September 1, 2017,
Mr. Markovich accused the Companies of not serving any timely discovery responses, even
though the Companies mailed discovery responses to Mr. Markovich at the 30 Wall Street,80'
Floor address. A true and correct copy of the September 1, 2017 email correspondence is
annexed as Exh. P.
20. Only after making the baseless accusation and receiving a proper rebuttal from the
Companies'counsel, did Mr. Markovich write back that "I just checked with our NY office and
they confirmed that they had received a package from you on August 29th but unfortunately, did
not notify me orforward."
Id
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IV. Site Visit to 30 Wall Street
21. On December 21, 2017, at about 1:15 PM, I went to 30 Wall Street to observe the
premises of the alleged New York office of U.S. Law Group to see if it is an actual office space
used by the attorneys.
22. However, the security guard at 30 Wall Street refused to grant me access to the8th
floor, stating that, without a prior scheduled appointment and his name being provided by a
tenant to security, no one would be permitted to go up to those offices. Notably, I did not
identify myself as a lawyer, stated that I needed access for legal business and was dressed
casually, and could have been mistaken for a process server.
23. Additionally, the guard told me that he had never heard of "U.S. Law Group"and
that tenants on the8th
floor of the building "sprout up likeflies."
Thus, it is clear that no one can
serve papers on Mr. Markovich at the 30 Wall Street address.
V. Conclusion
WHEREFORE, for all the foregoing reasons and as set forth in the accompanying
memorandum of law, the Court should disqualify Mr. Markovich and U.S. Law Group from
representing Plaintiff, as well as grant Crest Hill all such other and further relief as is just and
equitable.
Dated: New York, New York
December 14, 2017
JACOB H. NEMON
7
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EXHIBIT LIST
A. Notices of Appearance in Two Actions, May 2017
B. Nemon Letter to Markovich, May 15, 2017
C. Nemon Letter to Markovich, June 16, 2017
D. Markovich Letter to Nemon, June 21, 2017
E. Consents to Change Attorneys in Two Actions, December 14, 2017
F. U.S. Law Group"Attorneys"
Page
G. Naluda Magazine Interview of Usman Sheikh, dated November 19, 2017
H. U.S. Law Group Profile for John Buckman
I. Office Court Administration Listing for John Buckman
J. Buckman Group Homepage
K. LinkedIn Page of John Buckman
L. U.S. Law Group Homepage
M. Liquid Space Listing for 30 Wall Street,8th
FlOOr
N. Opus Virtual Offices Listing for 30 Wall Street,8th
Floor
O. Offices.net Listing for 30 Wall Street,8d'
Floor
P. Markovich Email to Nemon, dated September 1, 2017
8
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EXHIBIT A
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|F ILED : NEW YORK COUNTY CLERK 05 / 02 / 2017 12 : 5 0 PM1INDEX NO. 650404/2016
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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK
J-BAR REINFORCEMENT INC., Index No. 650404/2016
Hon. Saliann Scarpulla
Plaintiff,
-against NOTICE OF APPEARANCE
CREST HILL CAPITAL LLC and
MANTIS FUNDING LLC,
Defendants.
PLEASE TAKE NOTICE THAT, U.S. Law Group hereby appears as Attorneys of
Record on behalf of Plaintiff J-Bar Reinforcement Inc. ("Plaintiff")(" in the above-captioned action
and demands that a copy of all papers in this action be served upon the undersigned at the office
address stated below.
Beverly Hills, California
May 2, 2017
U.S. LAW GROUP
Raymond J. Markovich, Esq.
NY SBN 2582419
U.S. Law Group427 N. Canon Drive, Suite 206
Beverly Hills, California 90210
Tel: 212-634-4545
Fax: 212-634-4546
Attorneys for Plaintiff
of1 1
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("(" Plaintiff"
''~~
(FILED: NEW YORK COUNTY CLERK 05 /18 2017 11: 4 5 PM)INDEX NO. 650294/2017
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 05/18/2017
SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK
J-BAR REINFORCEMENT INC., Index No. 650294/2016
Hon. Saliann Scarpulla
Plaintiff,
-against NOTICE OF APPEARANCE
CREST HILL CAPITAL LLC and
MANTIS FUNDING LLC,
Defendants.
PLEASE TAKE NOTICE THAT, U.S. Law Group hereby appears as Attorneys of
Record on behalf of Plaintiff J-Bar Reinforcement Inc. ("Plaintiff") in the above-captioned action
and demands that a copy of all papers in this action be served upon the undersigned at the office
address stated below.
Beverly Hills, California
May 18, 2017
U.S. LAW GROUP
Raymond J. Markovich, Esq.
NY SBN 2582419
U.S. Law Group427 N. Canon Drive, Suite 206
Beverly Hills, California 90210
Tel: 212-634-4545
Fax: 212-634-4546
Attorneys for Plaintiffs
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EXHIBIT B
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CARTERLEDYARD&MILBURN LLP
Counselors at Law
Jacob H. Nemon 2 Wall StreetAssociaterlssuciale New York, NY 10005-2072
* 4 570 Lexington AvenueDirect Dial: 212.238.8728 Tel (212) 732-3200 New York,NY 10022-6856E-mail: [email protected] Fox (212) 732-3232 (212) 371-2720
May 16, 2017
BY EMAILRaymond J. Markovich, Esq.
U.S. Law Group30 Wall Street | 8th Floor |New York, NY I 10005
427 N. Canon Drive | Suite 206 | Beverly Hills, CA | 90210
T: +1-212-634-4545
F: +1-212-634-4546
Re: J-Bar Reinforcement, inc. v. Crest Hill Capital LLC, Index No. 650404/2016
J-Bar Reinforcement, Inc. v. Mantis Funding LLC, Index No. 650294/2017
Dear Mr. Markovich:
(" Hill"Hill"The firm represents Defendant Crest Hill Capital LLC ("Crest("
Hill") in the above-
referenced 2016 action, and Defendant Mantis Funding LLC ("Mantis";("("
together with Crest Hill,the "Defendants")
"Defendants""Defendants"in the above-referenced 2017 Action.
I see that you have filed a Notice of Appearance in the 2016 Action but not the 2017
Action, and I also see that The Law Offices of David J. Shapiro P.C. remains as counsel for J-
Bar Reinforcement, Inc. ("J-Bar") in both the 2017 Action and the 2016 Action. I am copyingMr. Shapiro on this correspondence. Please confirm that we should be addressingcorrespondence to both you and The Law Offices of David J. Shapiro P.C. as counsel for J-Bar
in connection with both actions.
It has come to our attention that both you and Ray Bouderau, the principal of J-Bar, have
attempted to communicate directly with Mr. Ed Lovette regarding this matter. As you are well
aware, Mr. Lovette was an officer and member of both Crest Hill and Mantis, and possesses
confidential and attorney-client privileged information about the companies and their financial
dealings (including those dealings with J-Bar and the ongoing litigations), which confidences
and privilege belong to the companies, cannot be waived or disclosed by Mr. Lovette, and which
you are not entitled to discover - either informally or formally. See Muriel Siebert & Co., Inc. v
Intuit Inc., 8 N.Y.3d 506 (2007). Moreover, given the fact that Mr. Lovette left the companies
prior to April 8, 2016, any information that he might have would be both outdated and irrelevant
to the limited issues on which the Court has required disclosures.
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pay"
Mr. Raymond J. Markovich, Esq./J-Bar
May 16, 2017
Page 2
At the April 19, 2017 hearing, the Court made it clear that limited disclosure was
required on two issues "the truth or the falsity of thatassertion" that the Senior Debt owed to
Dominion has not been paid (see Tr. p. 14; see also Tr. p. 17), and the "total number . . . to show
that [the Companies] are liquid [and] could afford topay"
a million dollar judgment. Thus, any
discovery of Mr. Lovette would not be reasonably calculated to the discovery of admissible
evidence. Accordingly, any further attempts to conduct informal or formal discovery of Mr.
Lovette would be nothing more than a transparent attempt to engage in the type of fishingexpeditions designed to harass the companies and their business partners that the Court found
objectionable (see Tr. at 13 and 18).
I trust that Eric Askenase, Esq., has informed both you and your co-counsel of the stern
comments that the Court made off the record regarding the impropriety of J-Bar's October 28,2016 letter and its empty accusations of collusion, and the warnings that it gave him regarding J-
Bar's future conduct.
Sincerely,
/s/ Jacob H. Nemon
Jacob H. Nemon
Cc: Jeffrey S. Boxer, Esq.
David J. Shapiro, Esq.
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EXHIBIT C
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CARTERLEDYARD&MILBURN LLP
Counselors at Law
2 Wall StreetJacob H. Nemon New York, NY 10005-2072
Associate ' 570 Lexington AvenueTel (212) 732-3200 New York,NY 10022-6856Direct Diah 212.238.8728 Fax (212) 732-3232 (212) 371-2720E-mail: nemon@cinLcom
June 16, 2017
BY EMAILRaymond J. Markovich, Esq.
U.S. Law Group427 N. Canon Drive, Suite 206
Beverly Hills, California 90210
Re: J-Bar Reinforcement, Inc. v. Crest Hill Capital LLC, Index No. 650404/2016
J-Bar Reinforcement, Inc. v. Mantis Funding LLC, Index No. 650294/2017
Counsel:
We acknowledge your appearance as co-counsel for J-Bar Reinforcement, Inc. ("J-Bar")in the above-referenced matters and respond to your request for a meet and confer concerning the
issue of supplemental briefing regarding the subsequent filing of a UCC-1 financing statement
by Mr. Edward Lovette's company.
At the outset, we note that it is Crest Hill Capital LLC's ("Crest("Hill") and Mantis
Funding LLC's ("Mantis")(" Mantis" position that such filings - which occurred after Mr. Lovette left
Crest Hill and Mantis and relinquished any ownership interests in those companies - had
absolutely no impact upon the J-Bar Subordination Agreement. Please feel free to advise us how
you believe that such subsequent filing is at all relevant or material to the J-Bar debt, or impacts
upon the fact that J-Bar cannot collect one cent until the Existing Lenders referenced in the
Subordination Agreement are paid off. I trust that you have had a chance to get yourself up to
speed on the case and have read the transcripts of the oral arguments at which the Court made
this point crystal clear and warned J-Bar not to bring any unsubstantiated allegations of collusion
to the Court.
In the unlikely event that you can come up with some non-frivolous theory regarding the
materiality of the UCC-1 filing on the issue of J-Bar's subordination, please explain to us how
and why it is that J-Bar failed to present this information in earlier briefing of the various
motions. We remind you that these proceedings are CPLR § 3215 motions for summaryjudgment in lieu of complaint, and there is no procedural justification for J-Bar, the plaintiff, to
submit extrinsic documents that are not a part of the Note or Subordination Agreement as part of
the briefing of those motions, or to "seek leave to amend [J-Bar's]complaint."
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RAYMOND J. MARKOVICH, Esq.
JUNE 16, 2017
PAGE 2
Last, perhaps your co-counsel did not fully brief you on the stern words that the Court
had during a side bar after the last oral argument for the conduct of J-Bar's principal and its co-
counsel in how they had exacerbated the dispute. The Court specifically stated that it was goingto reserve decision on the pending motions and expected that J-Bar would make a reasonable
settlement demand, that Crest Hill and Mantis would respond, and then the Court would hold a
settlement conference, if necessary. We await your reasonable settlement proposal and will
respond in due course.
Sin er y,
Jac b H. Nemon
Cc: Jeffrey S. Boxer, Esq.
David J. Shapiro, Esq.
1
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EXHIBIT D
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I'
—— C~c)—
u427 N. CANON DR1VE 30 WAU. STREET
SUlTE 206 8m FLOOR• • BEVERLY HIuÄ CA 90210 NEW YORK, NY 10005
T 877.821.8718 T 212.634.4545
F 310.870.7063 F 212.634.4546
June 21, 2017
Via Email
Mr. Jacob H. Nemon, Esq.
Carter Ledyard & Milbum LLP
2 Wall Street
New York, NY 10005-2072
Re: SETTLEMENT OFFERJ-Bar Reinforcement, Inc. v. Crest Hill Capital LLC, Index No. 650404/2016
J-Bar Reinforcement, Inc. v. Mantis Funding LLC, Index No. 650294/2017
Mr. Nemon:
I was traveling for a funeral and thus my delay in responding to your June 16, 2017
response ("Response")(" Response"
to our June 12, 2017 "meet andconfer"
letter. Our privileged settlement
offer is being sent concurrently in a separate letter.
I've read the transcript of the April 19, 2017 proceedings and your finn makes a
representation to the Court that J-Bar is "[i]n a secondposition"
behind Crest Hill and Mantis.
[Dkt. 23, p. 4:22-5:5]. But since you and your clients obviously knew about Mr. Lovette's June
3, 2016 UCC-1 filing, J-Bar might arguably now not be in second position because of this related
party filing.
As for whether Mr. Lovette would still be deemed a related party, that would require
discovery and your representations are inadequate especially in light of the foregoing. Looking at
this objectively, Mr. Lovette signed the subordination agreement but then went and filed a
security interest that arguably, absent my client prevailing on claims of fraud, conversion and/or
collusion against your clients and Mr. Lovette, put Mr. Lovette's company in a position senior to
J-Bar. This smells bad. I believe that this Court will see things as I do and you have a real
problem with your "secondposition"
representation.
As for why Mr. Lovette's June 3, 2016 UCC-1 filing was not presented earlier, I think
that you need to ask yourselves the question why you did not inform the Court? As for J-Bar, Mr.
Lovette's June 3, 2016 UCC-1 filing was done several months after Mr. David Shapiro initiated
this Action on behalf of J-Bar on January 26, 2016. Are you implying that Mr. Shapiro and J-Bar
should have assumed that your clients and Mr. Lovette would try to steal from J-Bar after the
Action was initiated?
As concerns extrinsic documents, while the summary judgment motion is still pending,the Court appears to have either ruled from the bench, or at least indicated what the decision
www.USLAwGROUPINC.COMIiNPo@USLA'vGRo 0PIinc.coM
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would be concerning the scope of discovery that would be allowed. [Dkt. 23, p. 16:6-20:23]. Mr.
Lovette's June 3, 2016 UCC-1 filing is extremely relevant to the scope of discovery that should
be allowed and this Court specifically asked if there was any evidence of collusion. [Dkt. 23, p.
15:19-16:4]. I see no procedural bar to supplemental briefing or this extrinsic evidence but 1
would be interested in any authority that you can present to support your assertion?
As for leave to amend, CPLR § 3215 is inapplicable. However, under CPLR § 3213, if
the summary judgment motion is denied, the moving papers become the equivalent of a
complaint and J-Bar can seek leave to amend. Fine v Di Stanti, 79 AD2d 673 [2d Dept 1980].
Obviously, J-Bar would also seek to join Mr. Lovette and his company.
We look forward to your response.
Sincerely,
/s/Raymond J. Markovich, Esq.
[email protected]* BBA,JD & LLM - in New York.
SCOTUS.2d 8 9th Circuits
cc: Usman Shaikh, Esq.
David J. Shapiro, Esq.
Jeffrey S. Boxer, Esq.
22
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.Plaintiff,'.Plaint','
J C.!
FILED: NEW YORK COUNTY CLERK 12 /14 / 2017 01: 31 PM|INDEX NO. 650404/2016
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/14/2017
SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK--------------------------------------- x
J-BAR REINFORCEMENT INC.,
Plaintiff, Index No. 650404/2016
: (Scarpulla, 1S.C.)-against-
: CONSENT TO CHANGECREST HILL CAPITAL LLC, ATTORNEY
Defendants.---------------------------------------- x
IT IS HEREBY CONSENTED that Raymond J. Markovich, Esq., be substituted as
attorney of record for the undersigned party in the above-titled action in place and stead of the
under-signed attorney as of the date hereof.
Dated: New York, New YorkDecember I2, 2017
THE LAW OFFICES OFDAVID J. SHAPIRO, P.C.
43 West 43rd Street, Suite 45
New York, New York 10036
Phone: (212) 265-2870
Outgoing Attorney
By: Isl David J. Shapiro
David J. Shapiro
U.S. LAW GROUP351 Westbourne Drive
West Hollywood, CA 90048
Phone: (323) 401-8032
Incoming Attorney
By: /s/ Raymond J. Markovich
Raymond J. Markovich
j.1 ofof 22
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/
0
tg PQI+Is(~~+
QUAUffEOQUAUFIEOINIHSRONXBBORXCOuNTYCOUNIY
fF ILED : NEW YORK COUNTY CLERK 12 /14 2017 01: 31 PM INDEX NO. 650404/2016
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/14/2017
J-Bar Reinf ment Inc.
By:
/ Ray/Bouderau
STATE OF NEW YORK )):
COUNTY OF NEW YORK )
On the 1th day of December in the year 2018. before me, the
undersigned, personally appeared Ray Bouderau, personally known to me or
proved to me on the basis of satisfactory evidence to be the individual whose name
is subscribed to the within instrument and acknowledged to me that he executed
the same in his capacity, and that by his signature on the instrument. the individual
executed the instrument,
ANGGLACOTTONOTARYPUBUC.8TATE0FNEWYORK
01C05272801
COMMISS EXPIRESEXPIRES SE ,Sl,XS,26
2
22 Ofof 22
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X
(FILED : NEW YORK COUNTY CLERK 12 /14 / 2017 01: 30 PM)INDEX NO. 6 5 0294 / 2 017
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/14/2017
SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK
J BAR REINFORCEMENT INC.,: Index No. 650294/2017
Plaintiff, (Scarpulla, LS.C.):
-against- CONSENT TO CHANGE: ATTORNEY
MANTIS FUNDING LLC,
Defendant.--------------------------------------- x
IT IS HEREBY CONSENTED that Raymond J. Markovich, Esq., be substituted as
attorney of record for the undersigned party in the above-titled action in place and stead of the
under-signed attorney as of the date hereof.
Dated: New York, New York
December 12, 2017
THE LAW OFFICES OFDAVID J. SHAPIRO, P.C.
43 West 43rd Street, Suite 45
New York, New York 10036
Phone: (212) 265-2870
Outgoing Attorney
By: /s/ David J. Shapiro
David J. Shapiro
U.S. LAW GROUP351 Westbourne DriveWest Hollywood, CA 90048
Phone: (323) 401-8032
Incoming Attorney
By: /s/ Raymond J. Markovich
Raymond J. Markovich
of1 2
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FILED : NEW YORK COUNTY CLERK 12 /14 2017 01: 30 PMlINDEX NO. 650294/2017
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 12/14/2017
J-Bar Reil eme
By:
R Bodderau
STATEOF NEW YORK )):
COUNTY OF NEW YORK )
On the [3__th day of December in the year 2018, before me, the
undersigned, personally appeared Ray Bouderau, personally known to me or
proved to me on the basis of satisfactory evidence to be the individual whose name
is subscribed to the within instrument and acknowledged to me that he executed
the same in his capacity, and that by his signature on the instrument, the individual
executed the instrument
ANGELACOTTONOTARYPUBUO,STATEOFNEWYORK
01C06272801QUALIREDFNBRONXCOUNTY
COMMISSIONEXPIRESNOVEMBER26,20
2
of22 of 22
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(9) Usman Shaikh Interview in Naluda Magazine | LinkedIn Page 1 of 6
U.S. LAW'~i. GROUP
Usman Shaikh Interview in Natuda
Magazine
Publishedon December5,2017
Usman Shaikh + FollowManagingAttomeyat U.S.LawGroup 6 25 F] I p)7 articles
[This article originally appeared on November 19,.r9,.79, 2017 in Naluda Magazine)
Entertainment lawyers, along with agents and studio execs, are a ubiquitous group in
Hollywood. However a few stand out above and beyond, based namely on deal flow
and client lists. No one fits this bill more than Usman Shaikh, managing attorney at his
eponymous Beverly Hills-based law firm, U.S. Law Group, who, over the last few
years, has come to be known as an up-and-comer in industry circles for his legal
acumen, understanding of entertainment deal··making, and New York street
smarts. Usman's unique background spans Wall St., where he was a corporate attorney,
all the way through Hollywood. This lightening in a bottle combo has given this Ivy
League grad the ability to not only rep film financiers and producers but also cutting
edge tech and media startups in burgeoning Silicon Beach, LA's startup hub analogous
to Silicon Valley. We recently caught up with Usman to find out what makes him tick,
Launching a business takes grit, launching a law _firm takes another
level ofgrit and dedication. At what moment did you decide that you
wanted to create and launch U.S. Law Group?
Thanks for having me, truly a pleasure.
knew early in my career that going off on my own to start a firm was something that I
would end up doing, I just didn't know when Pd be ready to do it. When I was in law
school at the University of Pennsylvania, most of my classmates, including pig fe sag<alt
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f'
(9) Usman Shaikh Interview in Naluda Magazine [ LinkedIn Page 2 of 6
wanted to graduate and work at "BigLaw"
primarily because law school geared us to
think that Big Law was the highest echelon of the legal profession. No one in law
school ever talked about hanging his own shingle or using her legal background to start
a business or anything even remotely entrepreneurial (I do think that times have
changed and this is no longer the case at most top law schools).
I ended up working at a large international firm in NYC and then a white shoe corporate
firm on Wall Street. It was around this time that I realized that I really didn't want to
continue down partnership track. I consider myself entrepreneurial with a vast array of
professional and personal interests, and I knew I needed a change or I'd be doing the
same thing for the rest of my career. That was the impetus for my move to LA (along
with my passion for the industry and connection to it...I studied theatre as an
undergrad), where I started work at a Top 4 talent agency to get a better understandingof show business.
During this time, the economy went through a downward shift and the entertainment
business in particular was hit hard because independent financing for films dried up.
There was also a paradigm shin in the legal profession, with clients, who still wanted
high level legal services, challenging the extraordinarily high and, perhaps, obnoxious
legal fees being charged by many law firms. That's when 1 left the agency and went off
on my own to start U.S. Law Group (which, by the way, stands for my name).
Being a partner-level attorney with a pedigreed legal background, 1 was, early on, able
to market myself as someone providing top tier legal services in highly specialized areas
of the law at client-friendly rates, something my competitors weren't doing or unable to
do. Today, we only have one junior attorney so our clients get senior level
representation at a fraction of the cost that large law firms charge, because we simply
don't have the overhead and bureaucratic red tape that they oñen have. All senior
attorneys at U.S. Law Group come from prestigious law firms, talent agencies, studios,
or production companies, and this background directly benefits our clients without the
hefty legal fees. Pd like to think that U.S. Law Group is not just a product of its time
but rather a leader in what I think is the new model of legal representation. That said,
my training as a Big Law attorney in NYC and the time 1 put in at the talent agency
taught me discipline and instilled a certain work ethic, which, in turn, has led to the
success of U.S. Law Group.
You have an incredible career and have worked with entertainment,
media start ups, music festivals, and much, more. How is it that
you're able to deliver results for such a broad array or clients? What
is it about you that makes you brings it all together?
I have a unique background in the sense that 1 worked as a corporate attorney on Wall
St. and then at a Hollywood talent agency. So my clients are generally a mix of these
two disciplines. On the corporate side, I'm general counsel to numerous new media
startups that are creating and distributing cutting edge content through various digital
platforms. UphoricTV is a great example of this; they're creating live stream and
original content forI' global music festival fans. On the entertainment side, I r rgt g e
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they'
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production companies and film financiers, which couples my finance background with
my entertainment background. Even though these deals are entertainment related, they
require an in-depth knowledge of and expertise in, among other things, equity and debt
investment structures and SEC compliance, in addition to industry-specific standards
and practices. In the last 12 months alone, our firm's clients have financed pictures like
Kevin Connelly's upcoming John Gotti starring John Travolta, The Clapper starring
Ed Helms, Tracey Morgan, and Mickey Gooch, London Fields starring Johnny Depp
and Billy Bob Thorton, Keepers with Gerard Butler, Emilio Estevez's upcoming The
Public starring Alec Baldwin and Taylor Schilling, and Tragedy Girls starring Josh
Hutcherson which is currently in theatres and has an 83% approval on Rotten Tomatoes.
And as you pointed out, I also provide production legal services for live events
including music festivals, the latest being OndaLinda in historic Careyes, Mexico in
November, which Vogue magazine recently called the lux Burning Man (for the record,
Fm a burner!).
Exciting! That all said, what is your favorite part about your job?
The best part ofmy job is interacting and working with such talented clients, many of
whom are thought leaders in their respective industries. Many times Fm amazed at what
accomplishing! I mentioned UphoricTV already, but other examples
are seatXchange which is revolutionizing the ticketing industry and another
client, SpineLOOP, is introducing an innovative and much-needed surgery technique to
the market. Clients like these inspire me to bring my A-game to the office every day.
Having a wide array of clients across different sectors can certainly be challenging but,
as part of what I do, I have to be able to have a deep understanding of myclients'
respective businesses and industries. 1 learn something new with each client and it
quenches my insatiable desire for knowledge and learning new things. Additionally,
unlike many other attorneys, I have the capability, through my network, to bring deal
flow to my clients, introduce them to strategic partners, help with financing their
projects, etc. Nothing brings me more joy than when I introduce my clients to each
other and a deal comes out of it, benefitting both parties. That is not lawyering, but
rather an innate desire put deals together and see my clients do well. I suppose that's the
entrepreneur side of my brain at work.
Just as a fun recommendation when working with entertainment
clients, whether it be producers, talent, etc., can you choose one area
oflaw that you think you think clients should be aware about to
better protect themselves?
rd probably say intellectual property. Most of U.S. Law Group's matters, whether
corporate, entertainment, or litigation, have an intellectual property component to them.
While clients don't need to be experts in IP (that's the attorney 's jobj, they should have
a general knowledge of it for their respective businesses. For example, on the film
finance or production legal side, we deal a lot with rights acquisitions (e.g., optioning a
literary work to adapt it for the screen), collateralizing copyrights to protect
investments, chain of title for scripts, and licensing deals for content distribnigJagQn the rd 0
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(9) Usman Shaikh Interview in Naluda Magazine [ LinkedIn Page 4 of 6
corporate side, we have to protect our startupclients' IP from inti·ingement, whether in
the form oftrademarks/tradedress/trade secrets, copyright of source code, or patents.
For our tech startup clients, we handle software licensing like SaaS deals and founders'
technology assignments, all of which have a heavy IP component. We currently have a
very high profile case in the 9th Circuit Court of Appeals which involves complex IP
issues.
What has inspired you to be a part of charitable projects? Is there a
certain cause thatreally stands out to you?
Regardless of how busy I am running U.S. Law Group, 1 always try to make time to
give back to those less fortunate than me. I think it has to do with my upbringing, myparents' commitment to charitable causes, and having seen deep poverty in other parts
ofthe world. Pve been raising money for and donating time to nonprofits since I was a
teen. Most recently, in August, U.S. Law Group sponsored an event for Give a 2nd
Chance, a nonprofit dedicated to providing second chances to those less fortunate than
us. especially veterans wounded in combat. We had the event at the famous The
Vineyard Beverly Hills attended by a great mix of our clients, friends, and LA's
influencers and tastemakers. We partnered with Sk8 4 Education, an inner city after
school skateboarding program. The event was tremendously successful in raising
awareness for the charity. Pm also on the board of directors of Give a 2nd Chance. so
it's a cause that's especially close to my heart. Additionally, over the past few years,
Pve gotten more and more involved with Russell Simmons' Foundation for Ethnic
Understanding, whose mission has become more relevant in these recent turbulent
times.
As digital strategy and new media rise, let's look to the future. What
is one small strategy that you advise businesses should be
implementing?
Pve written an article on this subject, Monetization of Social Media, available on U.S.
Law Group's website, among other platforms. I urge your readers to check it out!
Ok, now let's have a littlefim. Which one do you love more, New York
or Los Angeles and why?
I love and have deep respect for both cities. As you know, in addition to our Beverly
Hills location, we have an office on Wall St. and I'm licensed to practice law in both
states. It's really comparing apples to oranges (or a Big Apple to a California
Avocado?!) and each has its virtues and shortcomings. Pm proudly bi-coastal and love
having a presence in both cities. Is that too PC of an answer? Lol.
Speaking ofPC, we're seeing you becoming more involved in local
and national politics. What has inspired you to do that?
Pm a self admitted political junkie. While PveI' never held public office myself, I try to
fulfill my civic duty as an American and admirer of the democratic process. M9a$g 5 8
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(9) Usman Shaikh Interview in Naluda Magazine | LinkedIn Page 5 of 6
recently, PveI' taken a semi-official role in the campaign to elect Omar Qudrat to the
lJ.S. Congress in California's 52nd District. At the sake of sounding bias, Omar's
ideology and background make him the perfect politician in Washington in these
divisive times and a great hope for the future of this country. We need more young men
like Omar, who's a veteran and former prosecutor at the Department of Defense,
holding public office, and Pm more than happy to devote my time and resources to see
this through. Your readers should definitely learn more about Omar at electomar.com.
And the all the while, re becoming one ofthe most recognizable
young attorneys in LA!
da, 1 appreciate you saying that. Being the face of the firm, 1 have to be a bit high
profile. 1 have to be at certain events like award shows or premieres to network and
grow my business. But when 1 am out and about, it's usually with clients or colleagues.
1 guess that garnishes some attention around town, and l'm not one to shy away from
attention!
Let'sfocus in on Usman Shaikh. You have such wonderful
accomplishments ranging from your firm, U.S. Law Group, and
working with clients in diverse industries to devoting time to
charitable causes to dabbling in politics, Are you happy to look back
at the path you have taken? How does itfeel to be where you're at
today? What more will we be seeing from you?
That's a very loaded question! I think you'll continue to see U.S. Law Group provide
top tier legal services to its clients and expand by bringing on top talent. Our amazing
clients will continue to succeed in their respective endeavors. 1 truly love what I do and
count my blessings every day. And yes, l'm extremely happy with the path l'veI' taken,
the success of U.S. Law Group, and what the future holds for me, my firm, the other
attorneys at U.S. Law Group. and, perhaps above all, my clients.
Usman Shaikh is the founder and managing attorney of U.S. Law Group, a boutique bi-
coastal law firm providing innovative legal solutions in Corporate & Business,
Entertainment & New Media, Intellectual Property, and Litigation matters. To learn
more about Usman or U.S. Law Group,
please visit uslawgroupinc.com and facebook.com/uslawgroupine.
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John Buckman II U.S. Law Group Page 1 of 1
U.S. LAW° Abaur.Abouc PracticePracticeAreasAreas ° PressPress LegaiLegalArticfesAl'ticles ContactContact
GROUP
John BuckmanheadsU.S.LawGroup'sNewYorkoffice. His practicefocuseson Corporate,FinanceandStartupmatters,
Johnis the founderor co-founderof 3 tech-basedstartupcompaniesaswellas servingon the boardof directorsof a numberof privatecompaniesJohnis alsoChairmanof Cafrino- a California-basedanhnepoker businessand servesas GeneralManagerof KAYWEBAngels- a NYC-based"angeldevelopment"ctevelopmentfirm wherehe advisesa broadportfolio of start-upcompaniesandassessesdozensof
stari:-uppitcheseachyear,
With everydient, John bnngsof wealth of knowledgeas well as placticalstart-up expenence,thus
helpingto not only to guide the legalprocess.but offering informed insight into broaderbusinessJOHN B UCKMAN issuesfacingmanystanupømpanies.
i,; tn iBeforestrikingout on hisownin 2004to foundBuckmanGroup- CorporateCounsel,LLC0 boutique
BarAdmissions law firm servingthe NYCand NJinarkets.Johnworked for PitneyHardin(now Day Pitney)in New
+ NewYork Jerseyand Winston8 StrawnLLPin NewYork City,representinglargepubliccompanies,as well as
• Newjersey mediumandlargeprivatecompanies,indudingavarietyof techcompanies.
Education
• J.D..CreightonUniversitySchoolofLaw
* BuA.(English),UniversityofConnecticut
LOSANGELES NEWYORK ATTORNEYS RECENTPRESS&ARTICLES
427NorthCanonDrive 30WallStreet UsmanSharkh >UsmanShaikhInterviewinsuite206 8th Floor JohnBuckman NaludaMagazine
BeverlyHills,CA90210 NewYork,NY10005 vincentCastagna
Phone:877,821.8718 Phone:212.634.4545 JJ.Little>FalseAdvertisingCausedFyre
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
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Attorney Directory - Attorney Details https://iapps.courts.state.ny,us/attorney/AttorneyDetails?attorneyId=Istov...
- New Yo1·k State t offied ( otti·t Systent
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AttorneA/l//O> /yes Dek/III
Registrationas of 22/22/2027
A 3 1Olitt I,Y5Registered Registration Number: 4165874In-HouseCounselSearch JOHN BURR BUCKMAN IV 0 5
BUCKMAN GROUP - CORPORATE
In-HouseCOUNSEL LLC
Counsel11 S PASSALC AVE FL 2
Registration CHATHAM, NJ 07928-2379United States Caatcas
Resources (973) 507-0748
E-Courts E-mail Address: [email protected] 5 EA RCfI
Date Admitted in NY: 08/21/2003Appellate Division
Contact Us Department of Admission: 1Law School: CREIGHTON UNIVERSITYRegistration Status: DelinquentNext Registration: lan 2019
Disciplinary History: No record of public discipline
Search Again
The Detail Report above contains information that hasbeen provided by the attorneylisted, with the exception of REGISTRATION STATUS, which is generated from theOCA database.Every effort is made to insure the information in the databaseis accurateand up-to-date.
The good standing of an attorney and/or any information regardingdisciplinary actions must be confirmed with the appropriate AppellateDivision Department. Inforrnation on how to contact the AppellateDivisions of the Supreme Court in New York is available atwww.nycourts.qov/courts.
If the name of the attorney you aresearching for does not appear,pleasetry again with adifferent spelling. In addition, pleasebe advised that attorneys listed in this databasearelisted by the name that corresponds to their name in the Appellate Division Admissionsfile. There are attorneys who currently usea name that differs from the name underwhich they were admitted. If you needadditional information, pleasecontact the NYSOffice of Court Administration, Attorney Registration Unit at 212-428-2800.
www,NYcOURTS.gov +
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—
~Bio
BUCKMAN GROUp http://buckman-group.com/
WELCOME WHAT WE DO ABOUT JOHN OUR CLIENTS OUR PHILOSOPHY CONTACT US
What We Do Who We Are
Buckman Group-Corporate Counsel, LLC ("BGCC") John Buckrnanhas been providingcounselto corporateserves as outside general corporate counsel for our clients for more than 14years and has representedclients. We share our clients'dients' entrepreneurialspirit and FORTUNE100companiesas well as dozens of mid-offer services as corporatecounsel to innovatorsacross sizedcompanies.a variety of industries.To better serve our clients wecustomfit each relationship,offering billing on a flat-fee Learn moreabout John...basis, hourly,through equity investment or acombination.
Learn more- Articles
Our Philosophy
At BGCC,we seek to establishworking relationshipswith start-upsand other entrepreneurial-mindedbusinessesthat need experiencedand informedcorporate counsel.
Learn more...
CONTACT US SUBSCRIBE TO OUR NEWSLETTER973,507,9748 973,752,9193 Name973.867.3670
[email protected] EmailBuckmanGroup- Corporate CounselLLC11S. PassaicAvenue - ,- ,2nd FloorChatham,NJ 07928
Follow Us on Twitter...
© 2017, BuckmanGroup Corporate CounselLLC
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John Buckman
Entrepreneur, Attorney
tH«..f'W'Summary
I am a corporate attorney, working with start-ups and established businesses, large and small, in New Jersey and
New York City.
I am also a co-founder of 4 start-up companies and am actively involved in a growing portfolio of businesses.
Specialties: start-up strategy and implementation, M&A, IT and IP contracts, business counseling, licensing,
business development, compliance
Experience
Member / Owner
August 2009 - Present
At Buckman Group- Corporate Counsel, we thrive on the energy and innovation of the entrepreneur. Our
clients span a variety of industries, but share a determination to be leader in their markets..tnarkets. We make it our
job to provide legal and business counsel to these motivated entrepreneurs and we are constantly seeking
new opportunities with like-minded business people.
BGCC was fonned as an alternative to the traditional law firm. Our goal is to be a part of, and enhance,
innovation, and not simply provide a service for a fee. We look at our clients as collaborative partners who
want to expand their business team to include an experienced legal perspective.
Specialties: Commercial and technology contracts / IP licensing /<corporate governance / strategic
partnerships / marketing agreements and strategy / M.&A and corporate finance
Founding Partner, Chief Compliance Officer 4 General Counsel at Pin4
May 2013 - Present
HalCash North America is the company behind Pin4 Cardless Cash, an innovative financial services platform
that enables global person to person money transfers via the use of standard SMS messaging. Senders can
transfer funds directly from their bank account to anyone with a cell-phone. Recipients can withdraw funds
from any Pin4 member ATM or POS globally, without the need forf'
a card or a pre-existing relationship with
the recipient institution.
Co-Founder at Cross River Network
May 2011 - Present
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incubator
Cross River Network is a privately held company exclusively providing digital advertising and events
marketing to the NY Waterway ferry system.
General Counsel and VP of Partnerships at EZUniverse, Inc.
July 2009 - Present
EZUniverse@ Inc. (EZU), is a technology. headquartered in.Mahwah, N.J..N.J. Founded in 2002, the
company develops comprehensive management solutions designed to deliver operational intelligence and
management technology. The world-class products engineered by EZUniverse Inc. include EZLink™,
deployed at one of the world's largest banking institutions and 360iQ™, which is currently being deployed
throughout the world's biggest franchisee network.
Team Builder - Field Hockey 4 NCAA (East) at Sportle
July 2015 - Present
Sportle simplifies and enhances the live sports viewing experience, across all digital platforms.
General Counsel, Director
January 2017 - Present
General Manager, Director at KAYWEB Angels, LLC
August 2011 - Present
KAYWEB Angels, LLC is an angel investment group based in New York City, providing development
services and mentoring to web and mobile startups in exchange for equity.
The company is majority owned by KAYWEB, LLC - a web and mobile application development company
with offices and staff in Australia, the United States and the Philippines.
KAYWEB Angels endeavors to make its considerable design and engineering resources available to selected
startups,
www.KAYWEBAngels.com
Director at Cafrino
August 2011 - Present
Disrupting the US online poker scene with an answer to the government shutdown of the major poker
providers to American players.
www.caftino.com
A KAYWEB Angels company.
www.KAYWEBAngels.com
Director at You Need My Guy
Page 2
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you'you'
yout'
of'
October 2011 - Present
About You Need My Guy
[or gal] Who's Mine is Yours. The best way to organize referrals and recommendations. If re a service
provider, it's the only way to show your prospects how they know your current clients.
Join in at http://youneedmyguy.com!
http://Twitter,com/YouNeedMyGuy
http://Facebook.com/YouNeedMyGuy
A KAY WEB Angels investment. http://Kaywebangels.com
Director at Emercury.net
April 2010 - Present
At Emercury.net we believe in offering our clients cost effective marketing solutions forf'
their businesses.
Given the economic challenges that businesses are facing today we offer end to end email marketing services
that help our clients with customer relationship, customer feedback, and communication, all of these being
important to growth. Our email marketing.marketing services includes email marketing software that can automate your
emailing process, Our email marketing software also allows you to create and manage email campaigns and
is CAN-SPAM compliant. Another email marketing solution that we provide our clients with is bulk email
marketing. This is especially useful when you need to send out hundreds of thousands of emails. Whatever
your business requirements might be at emercury.net we definitely have a solution that caters to all your
needs making your business more successful. We have the best software in the industry along with trained
staff that is ready to be of assistance should you need any 24/7.
Specialties
Email Marketing, Email Sending, Email Blasting, Email Bulk Sending
Trustee at Chatham Field Hockey Club
May 2014 - Present
The Chatham Field Hockey Club serves to develop and promote community interest in the sport of field
hockey; to provide opportunities for participation in organized field hockey for all children in Chatham, and
to provide safe and proper training in the fundamentals of the sport.
http://chathamfieldhockeyclub.org/
Of Counsel at U.S. Law Group
April 2015 - Present
PagePage 33
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Co-Founder (NJ) at YumClub
January 2016 - Present
YumClub is a revolutionary new service, providing students on-demand ordering of meals that are both
healthy and nutritionist-approved, and well. yummy!
Trustee at GALS - Girls and Lifelong Strategies Inc.
January 2011 - October 2014 (3 years 10 months)
G.A.LS. is a 501c3 not-for-profit organization committed to improving the lives of women and children,
through fostering individual growth with the help of community-based partnerships. G.A.LS. is devoted to
the emerging needs of women and children, in.in addition to the greater good of society.
Director at Burringo
January 2011 - January 2013 (2 years 1 month)
Counsel at Budd Larner, PC
October 2007 - August 2009 (1 year 11 months)
Owner
June 2004 - October 2007 (3 years 5 months)
Associate at Winston 4 Strawn
2000 - 2004 (5 years)
Associate at Day Pitney LLP
1998 - 2000 (3 years)
Associate at Dillon Bitar & Luther
1996 - 1998 (3 years)
Edtication
University of Connecticut
BA, English, Communication Sciences, 1987 - 1991
ACAMSCertified Anti-Money Laundering Specialist, 2016
Creighton University School of Law
JD, Law, 1992 - 1995
Page 4
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John Buckman
Entrepreneur, Attorney
Linked
Contact John on LinkedIn
PagePage 55
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~E
U.S. Law Group | Los Angeles & New York Page 1 of 2
With offices in LosAngelesand NewYork,U.S.LawGroupis a boutique,bi-coastallaw firm providinginnovativelegalsolutionsin Corporate8 Business,Entertamment8 NewMedia,IntellectualProperty and Litigation.
LOSANGELES NEWYORK ATTORNEYS RECENTPRESS&ARTICLES
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W fth officesin LosAngelesand New 01Law Groupprides tselfon itsdedicationto 6 CORPORA1E&BUSINESSYork.U.S.LawGroupisa boutique,bi, clientservice.Weoffer the sophisticationof Big + EN'ItRTAINMEN'I&NEWMEDIA
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LOSANGELES NEWYORK ATTORNEYS RECENTPRESS& ARTICLES
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Capstone Executive Offices - 30 Wall Street | LiquidSpace Page 2 of 5
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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New York Virtual Office |30 Wall St. 8th Floor, New York, NY 10005 ~~$99 All Inclusive Page 3 of 3
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https;//www.opusvirtualoffices.corn/virtual-office/new-york/new-york/location-972https://www.opusvirtualoffices.corn/virtual-office/new-york/new-york/location-972 12/22/201712/22/2017
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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EXHIBIT 0
7817882.1
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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30 Wall St, 8th FI, Financial District, Manhattan - Office Space in NYC, NY
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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• .Williamsville- Yonkers
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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30 Wall Street Office Space Rental Manhattan Virtual Offices Page 6 of 9
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30 Wall St, 8th Fl, Financial District, Manhattan
Call now: 1-877-693-6433BookaTour RequestPrice AddtoShortlist
ServicedOffices from $800perpersonpermonth
This businesscenterwhich is stepsaway from all transit hasprovidedfurnishedoffices andvirtual office/businessservicesfor over 30 years.This centerprovidesyourwith a prestigiousWai1Streetaddress,all within a modern,beautifully appointedcorporatesettingincluding a fully attendedreceptionarea.Virtual offices are
alsoavailablestarting from $75 per month.
About the office location
This centerwhich is locatedon Wall Streetin betweenNassauStreetandWilliams Street,next to FederalHall and acrossfrom theNY StockExchange.It iseasilyaccessibleby public transportationincluding the 2, 3, 4, 5,J, M, Z, N andR trains,which isjust stepsaway.
Addto Shortlist Geta Quote Booka Tour
Office Services and Facilities
• Building Features- Air Conditioned• Carpeting
https://offices.net/ny/new-york-city/36867/ 12/22/2017
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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30 Wall Street Office Space Rental Manhattan Virtual Offices Page 7 of 9
• Americanswith Disabilities (ADA) CompliantThis office is compliant with theTheAmericanswith Disabilities Act of 1990(ADA), which wasenactedto prohibit discriminationagainstpersonswith disabilitiesin employmentand in accessto public entitiesandaccommodations.
• BusinessSupport• Admin & SecretarialServices• Copy Center• Multilingual Staff and Support• ManagementTeamOnsite• Mail Handling Services
Receiveyour mail at this addressandhaveit professionallyhandled.• Reception/ Lobby Area• PhoneAnswering Services
Professionalansweringservicefor your business'incoming calls.
• IT / Telecomms• High SpeedBroadbandAccess• CAT 6 Cabling or Above
EthemetCablefor high speednetworking.Category6 cableis a standardizedtwisted pair cablefor Ethernet,• IntegratedServicesDigital Network (ISDN)
ISDN allows the simultaneousdigital transmissionof voice,video, dataandothernetworkservicesover the telephonenetwork.• IT SupportAvailable
Technicalsupport is available,and canhelp with your computer,networkingandcommunicationssetup andmaintenance.• Video ConferenceFacilities
This office hasprofessionalvideoconferencingfacilities availableto makecommunicatingwith othercompaniesand branchesseamless.• Voicemail
The building featuresa centralizedelectronicsystemthat canstoremessagesfrom telephonecallers.• VOIP
Voice over InternetProtocol(VoIP) isan inexpensiveandconvenienttechnologythat allowsyou to makevoicecalls usinga broadbandInternetconnectioninsteadof a regularphoneline.
• Wi-FiThis office featureswirelessinternetconnectivity.
• Security• Building Access24/7• Day/Night Security• SecuritySystemand Intruder Detection
• Services& Amenities• Boardroom(s)
Boardroomfacilities areavailable.• Onsite Parking• CateringServices• CleaningServices• ConferenceRoom(s)• CyberCafe
This building featuresa cafethat offers Internetaccesson its computers,or via Wi-Fi on patrons'computers.• Gym• Kitchen Facilities• Meeting Room(s)
• WorkspaceFeatures• Near a CommuterRail Station• Near a Metro/SubwayStation• EasyIn / EasyOut• FurnishedWorkspace• ContemporaryBuilding• Virtual Office Solutions
A virtual office providesa businessaddressand/orphoneandmail handlingservices.Somevirtual office providerswill alsooffer day office rental,hot desking,meetingrooms,andother facilities or amenities.Virtual offices maybeofferedby businesscentersthatalsooffer monthly rentalof executivesuites,privateandsharedworkspaceandcoworking spaces.
This office spaceon 30 Wall St, 8th Fl, FinancialDistrict, Manhattan,NYC is availableimmediately.Detailsandpricesareavailableby calling 1-877-693-6433or bysubmitting the inquiry form.
https://offices.net/ny/new-york-city/36867/ 12/22/2017
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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• Carpeting• Americanswith Disabilities (ADA) Compliant• Admin & SecretarialServices• Copy Center• Multilingual Staff andSupport• ManagementTeamOnsite• Mail Handling Services• Reception/ Lobby Area• PhoneAnswering Services• High SpeedBroadbandAccess• CAT 6 Cabling or Above• IntegratedServicesDigital Network (ISDN)• IT SupportAvailable• Video ConferenceFacilities• Voicemail• VOIP• Wi-Fi• Building Access24/7• Day/Night Security• SecuritySystemand Intruder Detection• Boardroom(s)• OnsiteParking• CateringServices• CleaningServices• ConferenceRoom(s)• Cyber Cafe• Gym• Kitchen Facilities• Meeting Room(s)* Neara CommuterRail Station• Neara Metro/SubwayStation• EasyIn / EasyOut• FurnishedWorkspace• ContemporaryBuilding• Virtual Office Solutions
Pleasefill out the short form at thetop of this pageto get full information aboutthis office space,including the bestrentalpriceswe haveavailable.Click herefor otheroffice spaceandexecutivesuitesto rent in NYC,
https://of1Ices.net/ny/new-york-city/36867/https://offices.net/ny/new-york-city/36867/ 12/22/201712/22/2017
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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https://offices,net/ny/new-york-city/3 6867/ 12/22/2017
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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EXHIBIT P
7817882.1
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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.J
Nemon, Jacob H.
From: Raymond Markovich <[email protected]>
Sent: Friday, September 01, 2017 3:33 PM
To: Nemon, Jacob H.
Cc: Usman Shaikh
Subject: Re: J-Bar - "Meet andConfer"
Jacob: In most cases, we accept email so no headaches with the mail. I just checked with our NY office and
they confirmed that they had received a package from you on August 29th but unfortunately, did not notify me
or forward. They are forwarding now. Best, Ray
Raymond J. Markovich, Esq.
U.S. Law Group30 Wall Street | 8th Floor | New York, NY | 10005
427 N. Canon Drive | Suite 206 | Beverly Hills, CA | 90210
T: +1-212-634-4545
F: +1-212-634-4546
http://www.uslawgroupinc.com
http://www.imdb.me/rimarkovich
BBA, JD & LLM - Admitted in NY,
SCOTUS, 2d 4 9th CircuitsNY Licensed Real Estate BrokerPaid Federal Tax Preparer
THIS IS A CONFIDENTIA L COMMUNICATION protectedby theattorney-clientprivilegeandthework productdoctrine.This communicationmaynot be forwarded(otherthanwithintherecipientto which it hasbeensent)withoutour expresswritten consent.Ifyou arenotthe intendedrecipientof thiscommunication,pleasedeleteit immediatelywithoutopeninganyattachments.Pleasenotify thesenderby replye-mail thatyoureceivedthise-mail in error or call +1-323-401-8032.
IRS Circular 230Disclaimer:To ensurecompliancewith IRSCircular230,any U.S.federaltax adviceprovidedin this communicationis not intendedor written to beused,andit cannotbeusedby therecipientor anyothertaxpayer(1) for thepurposeof avoidingtax penaltiesthatmaybe imposedon therecipientor anyothertaxpayeror (ii) in promoting,marketingor recommendingto anotherparty,apartnershipor otherentity, an investmentplan,arrangementor othertransactionaddressedherein.
Subject To Written Agreement:Any purportedoffer or acceptancecontainedaboveissubjectto executionof a writtenagreementby all partiesto suchagreementandthereis noaureementuntil executionby all partiesofsuchwritten aureement.
Sep 1, 2017, at 12:00 PM, Nemon, Jacob H. <[email protected]> wrote:
We served last week. You did not receive?
JACOB H. NEMONAssociate
CARTER LEDYARD & MILBURN LLP
1
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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Two Wall Street | New York, New York 10005<x-apple-data-detectors://3/1>
Direct: (212) 238-8728<tel:(212)%20238-8728> | Fax: (212) 732-3232<tel:(212)%20732-3232>
Email: [email protected]<mailto:[email protected]> | Website:
www.cIm.com<http://www.clm.com/>
Sent from my iPhone
On Sep 1, 2017, at 2:59 PM, Raymond Markovich
<[email protected]<mailto:[email protected]» wrote:
Jacob:
We have received no response and no documents from you by the production date. Your
opportunity to object has passed. Please be advised that if we do not received all demanded
documents by September 5, 2017, we will be serving a motion to compel.
Best,
Ray
Raymond J. Markovich, Esq.
U.S. Law Group30 Wall Street | 8th Floor | New York, NY | 10005
427 N. Canon Drive [ Suite 206 I Beverly Hills, CA | 90210
T: +1-212-634-4545
F: +1-212-634-4546
[email protected]<mailto:[email protected]><mailto:[email protected]>
http://www.uslawgroupinc.com<http://www.uslawgroupinc.com/>
http://www.imdb.me/rimarkovich<http://www.imdb.me/rimarkovich>
BBA, JD & LLM - Admitted in NY,
SCOTUS, 2d & 9th Circuits
NY Licensed Real Estate Broker
Paid Federal Tax Preparer
THIS IS A CONFIDENTIAL COMMUNICATION protected by the attorney-client privilege
and the work product doctrine. This communication may not be forwarded (other than within the
recipient to which it has been sent) without our express written consent. If you are not the
intended recipient of this communication, please delete it immediately without opening anyattachments. Please notify the sender by reply e-mail that you received this e-mail in error or call
+1-323-401-8032.
IRS Circular 230 Disclaimer:
To ensure compliance with IRS Circular 230, any U.S. federal tax advice provided in this
communication is not intended or written to be used, and it cannot be used by the recipient or
any other taxpayer (I) for the purpose of avoiding tax penalties that may be imposed on the
recipient or any other taxpayer or (ii) in promoting, marketing or recommending to another party,
a partnership or other entity, an investment plan, arrangement or other transaction addressed
herein.
2
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
73 of 75
Subject To Written Agreement:
Any purported offer or acceptance contained above is subject to execution of a written agreement
by all parties to such agreement and there is no agreement until execution by all parties of such
written agreement.
Begin forwarded message:
From: Raymond Markovich
<[email protected]<mailto:[email protected]><mailto:[email protected]>
>
Subject: J-Bar
Date: July 27, 2017 at 11:53:34 AM PDT
To: "Nemon, JacobH."
<[email protected]<mailto:[email protected]><mailto:[email protected]»
Jacob:
Please see attached which are also sent by mail today.
I will also be sending out deposition subpoenas but thought best if I first check availability with
you and also whether Mr. Marano's depo would be in NYC or FL or by video. Pm fine with
video if that works for you?
How is his availability on September 6-8?
Best,
Ray
Raymond J. Markovich, Esq.
U.S. Law Group30 Wall Street ] 8th Floor | New York, NY | 10005
427 N. Canon Drive | Suite 206 | Beverly Hills, CA | 90210
T: +1-212-634-4545
F: +1-212-634-4546
ray·@uslawgroupinc.com<mailto:[email protected]><mailto:[email protected]>rayhttp://www.uslawaroupinc.com<http://www.uslawgroupinc.com/>
http://www.imdb.me/rimarkovich<http://www.imdb.me/rimarkovich>
BBA, JD & LLM - Admitted in NY,
SCOTUS, 2d & 9th Circuits
NY Licensed Real Estate Broker
Paid Federal Tax Preparer
33
FILED: NEW YORK COUNTY CLERK 12/22/2017 04:32 PM INDEX NO. 650294/2017
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
74 of 75
THIS IS A CONFIDENTIAL COMMUNICATION protected by the attorney-client privilege
and the work product doctrine. This communication may not be forwarded (other than within the
recipient to which it has been sent) without our express written consent. If you are not the
intended recipient of this communication, please delete it immediately without opening anyattachments. Please notify the sender by reply e-mail that you received this e-mail in error or call
+1-323-401-8032.
IRS Circular 230 Disclaimer:
To ensure compliance with IRS Circular 230, any U.S. federal tax advice provided in this
communication is not intended or written to be used, and it cannot be used by the recipient or
any other taxpayer (I) for the purpose of avoiding tax penalties that may be imposed on the
recipient or any other taxpayer or (ii) in promoting, marketing or recommending to another party,a partnership or other entity, an investment plan, arrangement or other transaction addressed
herein.
Subject To Written Agreement:
Any purported offer or acceptance contained above is subject to execution of a written agreement
by all parties to such agreement and there is no agreement until execution by all parties of such
written agreement.
<Document Demand - Crest Hill w POS - 072717 - sRJM.pdf>
<Document Demand - Mantis Funding w POS - 072717 - sRJM.pdf>*****************************************************
This e-mail message and its attachments are confidential, intended only for the addressee(s)named
above and may contain information that is proprietary, privileged, attorney work product or
otherwise
exempt from disclosure. If you receive this message in error please notify us at
and immediately delete this message and its attachments from your system.
4
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NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 12/22/2017
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