Suppression of Barch's subpoenaed documents until after Dulberg's deposition

Subpoena first sent on October 2#, 2019.  (Dulberg had been asking Williams to subpoena Barch since July, 2019.)

Beilski info:

RE Dulberg AOIC Claim No 13277911.pdf  (page 31 top email has 3 red flags)

a)  All dates in the 36 page email chain are November and December, 2019 except a single email that is dated February 19, 2020

b)  All emails in the 36 page chain have a warning regarding attorney client privilege and unauthorized use of email except one.

c)  The dialog makes no sense as there is an inexplicable 5 week delay which is ignored by both parties


Dulberg v Popovich et al.pdf


December 17, 2019 email Williams to Flynn

In Dulberg matter Ed Clinton there is a folder called "..."  The files in the folder were created ...

In Dulberg Master File there is a folder called "Barch production complete"


page 26 same pdf:


From: Julia WIlliams juliawilliams@clintonlaw.net
Subject: Re: Dulberg v Popovich et al
Date: January 29, 2020 at 2:16 PM
To: George Flynn gflynn@KARBALLAW.COM
Cc: ed@clintonlaw.net, marywinch@clintonlaw.net


2. Chantel Bielskis of Cicero France & Alexander reached out asking for more time to respond to our subpoena to their office. I have
granted her more time and working on getting information from her.

We sent you the files, I believe.





Dulberg argument against depositions without access to Barch documents:

Barch Documents.pdf

and

2020-02-22_Re Barch Documents 8.pdf (In Mojave/legal documents/clinton/...)


2020-02-06_PM-13-05_Re Dulberg v Mast et al Discovery and Court Order.pdf (in samsung/clinton emails...)


On March 4, 2020 email






>>>>>>>>>>>>>>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>>>>>>>>>>>>>>>



page 51 of 107 file Dulberg v Popovich et al.pdf


From: Julia WIlliams juliawilliams@clintonlaw.net
Subject: Re: Dulberg v Popovich et al
Date: January 31, 2020 at 11:21 AM
To: George Flynn gflynn@karballaw.com
Cc: Ed Clinton ed@clintonlaw.net, Mary Winch marywinch@clintonlaw.net
Thanks George.
I will give you buzz later today (we are getting new phones right now).
We can reschedule the review of Mast’s file. I would like to get that done before we move forward with depositions.
As to RFP 4 and 5, yes, if we have further responsive documents we will produce them in a supplement. I believe we have produced
everything in the client’s possession and control as he advised that he turned everything over to us. In my last email, I was specifically
referring to the interrogatories only .
Best Regards,
Julia Williams