Free Reply in Support of Motion - District Court of Arizona - Arizona

EXHIBIT 2
Case 2:04-cv-OOO78-FJIVI Document 186-5 Filed O3/18/2008 Page1 of 2

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Rima M. LaMont
From: David AWeIIing Esq [davidanthony1@|ycos.com]
Sent: Tuesday, March 18, 2008 2:25 PM
To: Roger L. Cohen
Cc: [email protected]; [email protected]; [email protected]; Rima M. LaMont;
[email protected]
Subject: [RE]Ross adv Shimko
Roger,
You have misrepresented our telephone conversation. I never said that I will make all the arrangements
for you. You called me today at 5 minutes to 5:00 pm EST and stated that your assistant was having
trouble finding a court reporter in the Caymans. You told me that your assistant called a law finn in the
Caymans (which contact our office provided you), and that they were unable to help your assistant. I
told you that I have never set up a deposition in the Caymans before, and it is not my task to do that for
you. I told you that you should call a court reporter down there and set something up. You then asked if
I could check with my office staff to see if we could help you any further in setting up your deposition. I
told you that I would look into it. As such, when I speak with Mr. Shimko tomorrow morning, I will talk
to him about this issue. Iwill call you after I speak with him. Again, I have not agreed to act as your
paralegal and set up your depositions! .
Sincerely,
David A. Welling
—-—-—---— [ Received Mail Content ] --------·—
Subject : Ross adv Shimko
Date: Tue, 18 Mar 2008 14:14:59 -0700
From : "Roger L. Cohen"
To : "David A Welling Esq" ,
Cc : ,,"Rima M. LaMont"

David —
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Case 2:04-cv-00078-FJM

Document 186-5

Filed 03/18/2008

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Case 2:04-cv-00078-FJM

Document 186-5

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