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Friday, July 29, 2011 2:55:28 PM
That afternoon, on May 17,201 I, defendant reduced the offer to writing. It was somewhat
24 different than what was discussed because Mr. Lotta proposed stipulating to release the funds rather
25 than dismissing the action. Pinnacle indicated that it would need information on how such a
26 stipulation would work before agreeing to do so, reminded Mr. Lotta that a financial affidavit was
27 necessary, and indicated it would need all the information on the location of Mr. Kassab and Mr.
28 Liverette. Mr. Lotla indicated a financial affidavit would be "no problem" and that he would
DMl\273l850,J 4
Ex Parte Application to (1) Compel the Personal Appearance of Michael Lotta, (2) Discuss Service of the CrossComplaint
(3) Shorten Time to Hcar Motion To Release FUnds in Interpleader (4) Stay Defs' Molion to Compel
• •
I provide the information on the whereabouts of Mr. Kassab and Mr. Liverette right away. He also
2 stated stipulating to release the funds was simple and a friend of his has done it many times.
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