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08/03/16 11:31 AM

#9005 RE: honestengine_rh #9004

Why we don't see a spike of the share price?

honestengine_rh

08/03/16 11:36 AM

#9006 RE: honestengine_rh #9004

388 Market St., Suite 1300
San Francisco, CA 94111
Steven S. Kaufhold
skaufhold@kaufholdgaskin.com
VIA ECF
August 2, 2016
Hon. Richard Berman
United States District Court for the Southern District of New York
Daniel Patrick Moynihan Courthouse
500 Pearl Street
New York, NY 10007
Re: In re Longwei Petroleum Investment Holding Limited Securities Litigation, Case
No. 13cv214 (RMB) (RLE)

Dear Judge Berman:

We represent Defendants Michael Toups, Gerald DeCiccio, and Douglas Cole
(collectively, “Defendants”) in the above-referenced securities action. We are writing in
response to correspondence submitted to your Honor today by Plaintiffs’ counsel Stuart Guber
requesting an emergency conference regarding funding of the settlement in the above-entitled
action.
While we disagree with certain of the factual assertions in counsel’s correspondence and
do not believe that correspondence with the Court is the proper forum for debating aspects of a
confidential mediation process, we do agree that the settlement has not been fully funded and
that a conference before your Honor is appropriate and would be helpful. To that end, I can be
available telephonically for such a conference for the remainder of this week as well as on
August 9-10, 2016. I can also be available in person for such a conference on August 15-18,
2016.
We appreciate your consideration and assistance.
Sincerely,
/s/
Steven S. Kaufhold
Case 1:13-cv-00214-RMB-RLE Document 283 Filed 08/02/16 Page 1 of 1

honestengine_rh

08/03/16 11:36 AM

#9007 RE: honestengine_rh #9004

388 Market St., Suite 1300
San Francisco, CA 94111
Steven S. Kaufhold
skaufhold@kaufholdgaskin.com
VIA ECF
August 2, 2016
Hon. Richard Berman
United States District Court for the Southern District of New York
Daniel Patrick Moynihan Courthouse
500 Pearl Street
New York, NY 10007
Re: In re Longwei Petroleum Investment Holding Limited Securities Litigation, Case
No. 13cv214 (RMB) (RLE)

Dear Judge Berman:

We represent Defendants Michael Toups, Gerald DeCiccio, and Douglas Cole
(collectively, “Defendants”) in the above-referenced securities action. We are writing in
response to correspondence submitted to your Honor today by Plaintiffs’ counsel Stuart Guber
requesting an emergency conference regarding funding of the settlement in the above-entitled
action.
While we disagree with certain of the factual assertions in counsel’s correspondence and
do not believe that correspondence with the Court is the proper forum for debating aspects of a
confidential mediation process, we do agree that the settlement has not been fully funded and
that a conference before your Honor is appropriate and would be helpful. To that end, I can be
available telephonically for such a conference for the remainder of this week as well as on
August 9-10, 2016. I can also be available in person for such a conference on August 15-18,
2016.
We appreciate your consideration and assistance.
Sincerely,
/s/
Steven S. Kaufhold
Case 1:13-cv-00214-RMB-RLE Document 283 Filed 08/02/16 Page 1 of 1