--- type: court_doc id: "court_ctb_1805_43" court: "CTB" case_no: "22-50073" doc_number: 1805 doc_type: "RESPONSE" filed_date: "2023-05-18" lang: "zh" url: "https://mubeitech.com/court/court_ctb_1805_43" json_url: "https://mubeitech.com/api/court/court_ctb_1805_43" --- # Gzjkdkv!# | From: | Fornos. Carolina A. > 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。 # Gzjkdkv!# | From: | Fornos. Carolina A. | |--------------|--------------------------------------------------------------------------------------------------------| | TO: | Kosciewicz. Jonathon P. | | CC: | Luft, Avi E .; Akuffo, Kwame O .; Farmer, Will C .; Sutton, Ezra; Patrick Linsey; Kellianne Baranowsky | | Subject: | [EXT] RE: G Club Rule 2004 Subpoena | | Date: | Sunday, April 9, 2023 8:03:50 AM | | Attachments: | image001.png | #### -- External Email --- Dear Jonathon, Good morning. The Trustee's email, late on Thursday night, demanding production of all documents by Monday at noon is unreover, it is not warranted. GClub has tried on several occasions to narrow the scope of the Trustee's document request in response to the objections we have shared with you, but the Trustee has not once responded with any reasonable accommodation. Reuping the Trustee's demand wholesale flies in the face of expected effort among parties to narrow discovery disputes. Moreover, GClub has been busy understanding the charges that have been filed and how they impact the Trustee's request, the chapter 11 cases and appropriate next steps. This makes it impractical, if not impossible, to provide you all of the information, especially the overreaching information, requested by your deadline. These challenges are in addition to a demand to produce documents over Easter weekend (not to mention during Holy Week and Passover). GClub remains available to meet and confer to narrow the overly broad document requests you have made. Please propose a time this week so we can discuss scope and a reasonable time frame to produce documents. Regards, Carolina From: Kosciewicz, Jonathon P. Sent: Thursday, April 6, 2023 9:53 PM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo@pilsburylaw.com>; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey ; Kellianne Baranowsky Subject: RE: G Club Rule 2004 Subpoena #### Hi Carolina, During our last meet and confer, you indicated that you would let us know what, if any, action your client was going to take regarding the findings made by the Bankruptcy Court in its Preliminary Injunction Decision. We have not heard from you since. The deadline for your client to produce documents responsive to its Rule 2004 Subpoena was lanuary 9, 2023. Despite good faith attempts to meet and confer regarding your client's responses and objections, the Trustee has not responsive documents. As of our last meet and confer, your client was unwilling to engage further on various issues as a result of purported disagreements during the meet and as a result of the Bankruptcy Court's findings with respect to G-Club. Given your client's failure to comply with the Rule 2004 Subpoena thus far and the lack of progress during our meet and confer discussions, we are requesting that G-Club Operations, LLC complete its entire production of documents (including privilege log(s)) on or before April 10, 2023 at 12:00 PM Eastern. We otherwise intend to seek the assistance of the Court. We are available to meet and confer regarding the foregoing tomorrow to the extent that would be productive. Best, Jon Jonathon P. Kosciewicz | Associate, Litigation Department PAUL Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: HASTINGS =1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | | From: Fornos, Carolina A. Sent: Monday, March 6, 2023 5:52 AM To: Kosciewicz, Jonathon P. < jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey ; Kellianne Baranowsky Subject: [EXT] RE: G Club Rule 2004 Subpoena ### --- External Email --- Hi Jonathon, Good morning. Confirming that Tues at 1pm works. Thank you. Carolina From: Kosciewicz, Jonathon P. Sent: Sunday, March 5, 2023 11:55 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey ; Kellianne Baranowsky Subject: RE: G Club Rule 2004 Subpoena Hi Carolina, Does Monday at 3ET work for you? Otherwise, I have available anytime on Tuesday between 1ET—4ET. Let me know what works for vou. Thank you, lon Jonathon P. Kosciewicz | Associate, Litigation Department PAUL Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: HASTINGS +1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | 14.49.11.312.499.6021 | Main: +1.312.499.600 | www.paulhastings.com From: Fornos, Carolina A. Sent: Friday, March 3, 2023 3:38 PM To: Kosciewicz, Jonathon P. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey ; Kellianne Baranowsky Subject: [EXT] RE: G Club Rule 2004 Subpoena --- External Email --- Jonathon, Would you have time to connect Monday afternoon or any time Tuesday? This week was more hectic than anticipated. And I will be traveling next Wed-Fri and the week after so if we can schedule a time before then, that would be best. Additionally, I would appreciate it if you could add Kellianne Baranowsky. Given my travel schedule in the coming weeks, I think this makes most sense. Regards, Carolina From: Kosciewicz, Jonathon P. Sent: Tuesday, February 28, 2023 12:16 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame.akuffo@pillsburylaw.com>; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: RE: G Club Rule 2004 Subpoena Hi Carolina, My Wednesday afternoon is mostly free. Are you available, say, 2 pm ET on Wednesday? Thank you, Jon Jonathon P. Kosciewicz | Associate, Litigation Department PAUL P A U L From: Fornos, Carolina A. Sent: Friday, February 24, 2023 7:29 AM To: Kosciewicz, Jonathon P. < jɔnathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: [EXT] RE: G Club Rule 2004 Subpoena --- External Email --- Dear Jonathon, Good morning. l have conflicts this afternoon. Could you do Mon/Tues/Wednesday of next week? Regards, Carolina From: Kosciewicz, Jonathon P. Sent: Thursday, February 23, 2023 11:27 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: RE: G Club Rule 2004 Subpoena Hi Carolina, Apologies for the delay. Are you available late tomorrow afternoon to have a call? Say 4PM ET, or later? Thank you, Jon Jonathon P. Kosciewicz | Associate, Litigation Department PAUL Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: HASTINGS +1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | From: Fornos, Carolina A. Sent: Friday, February 17, 2023 2:54 PM To: Kosciewicz, Jonathon P. < jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: [EXT] RE: G Club Rule 2004 Subpoena --- External Email --- Dear Jonathon, Thank you for the protective order. Are you and Avi available early next week for a follow up call on the Trustee's position on the Rule 2004? Thank you. Carolina From: Kosciewicz, Jonathon P. Sent: Friday, February 10, 2023 1:04 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: RE: G Club Rule 2004 Subpoena Carolina, It was nice speaking with you today. Attached, please find the Protective Order that has been entered in this case. Thank you, Jon Kosciewicz ![](_page_5_Picture_5.jpeg) Jonathon P. Kosciewicz | Associate, Litigation Department Johallion' P. KUSClewicz | Associate, Eligación Departilient Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: < 1.212.499.6021 | Main: + HASTINGS +1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | Hain: +1.312.499.6021 | Main: +1.312.499.600 | www.paulhastings.com From: Fornos, Carolina A. Sent: Thursday, February 9, 2023 6:14 AM To: Kosciewicz, Jonathon P. < jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: [EXT] RE: G Club Rule 2004 Subpoena #### --- External Email --- Good morning. Apologies for the delay. Yes - today at 2pm works. Regards, Carolina From: Kosciewicz, Jonathon P. Sent: Wednesday, February 8, 2023 10:32 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: RE: G Club Rule 2004 Subpoena Hi Carolina, We have availability Thursday afternoon. Does Thursday at 2PM ET work? If so, I will circulate a dial in. Thank you, lon ![](_page_5_Picture_17.jpeg) From: Fornos, Carolina A. Sent: Monday, February 6, 2023 4:23 PM To: Kosciewicz, Jonathon P. < jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: [EXT] RE: G Club Rule 2004 Subpoena # --- External Email --- Dear Jonathon, Good afternoon. This week, the best windows on my end are Wed late afternoon (after 1:30pm and any time Friday. Let us know what works. Regards, Carolina From: Kosciewicz, Jonathon P. Sent: Friday, February 3, 2023 10:28 AM To: Fornos, Carolina A. Cc: Luft, Avi E. ; Akuffo, Kwame O. ; Farmer, Will C. ; Sutton, Ezra ; Patrick Linsey Subject: RE: G Club Rule 2004 Subpoena Hi Carolina, We are in receipt of G Club Operations LLC's Responses and Objections to their Rule 2004 Subpoena to Produce Documents. What is your availability next week to meet and confer regarding these Responses and Objections? Thank you, lon Kosciewicz ![](_page_6_Picture_9.jpeg) From: Fornos, Carolina A. Sent: Monday, January 9, 2023 8:18 PM To: Patrick Linsey Cc: Luft, Avi E. ; Kosciewicz@paulhastings.com>; Akuffo, Kwame O. Subject: [EXT] G Club Rule 2004 Subpoena --- External Email --- Dear Patrick, Please see attached. We can discuss at your convenience. 10 Regards, Carolina Carolina A. Fornos | Partner Pillsbury Winthrop Shaw Pittman LLP 31 West 52nd Street | New York, NY 10019-6131 t +1.212.858.1558 carolina.fornos@pillsburylaw.com | website bio The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770. Option 1. immediately by telephone and delete this message. along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain in that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain int is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com, The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com. The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com. The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com The contents of this message, together with any attachments, are intended only for the individual or entity to which they are addressed and may contain that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you. This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com The contents of this message, together with any attachments, are intended only for the use of the individual or entity to which # Case 22-50073 Doc 1805-43 Filed 05/18/23 Entered 05/18/23 23:05:44 Page 10 of 10 they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Service Desk at Tel: 800-477-0770, Option 1, immediately by telephone and delete this message, along with any attachments, from your computer. Nothing in this message may be construed as a digital or electronic signature of any employee of Pillsbury Winthrop Shaw Pittman. Thank you.