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Re: Manhattan Club Lawsuit (by Margo R.):

Mr. Zimmerman has been working tirelessly on our behalf. I am posting a recent update below. It is obvious that a great deal of time and research has been done to move this case forward. Issues such as the ones we all have with the Manhattan Club are not resolved easily. They take time, money, patience and determination. WE are all in this together. Please consider participating in this action - there is power in numbers. Together, we can succeed.

UPDATE FROM ZIMMERMAN LAW GROUP:

Good Morning,

We are writing to provide you with an update regarding our efforts on your behalf vis-à-vis TMC. Going forward we will provide you with such updates on a regular basis.

We are presently engaged in ongoing actions in New York State Supreme Court to obtain TMC’s member list and inspect TMC’s books and records on behalf of particular TMC members. Not surprisingly, TMC is strenuously fighting our efforts. The information ultimately obtained from these efforts may likely be used in the federal court action (described in your retention agreement) that we are preparing and intend to file this summer.

These ongoing efforts in New York State Supreme court include the action we filed on behalf of Robert Tucker last August. At a hearing held last December, Judge Lebovits instructed the parties to try and work together to resolve their dispute. These efforts failed because of TMC’s unwillingness to cooperate, and resulted in our recent filing of the following papers (copies attached hereto) to seek an Order to Show Cause on which oral argument before the Court was just scheduled to be held on April 1, 2019:

1. Verified Complaint;

2. Memo of Law;

3. Affidavit of Robert Tucker;

4. Affidavit of Jean-Marc Zimmerman;

5. Exhibits 1-10 to Zimmerman Affidavit;

6. Order to Show Cause;

7. Request for Judicial Intervention;

8. Request for Judicial Intervention Addendum; and

9. Summons.

After the foregoing papers were filed, TMC filed a letter that sought to thwart our efforts to attain the relief we are requesting by attempting to have the case assigned to a different judge who is not familiar with Mr. Tucker’s case. In response, we submitted a letter identifying various inaccuracies and omissions in TMC’s submission, with the result being that the case is still before Judge Lebovits. Copies of TMC’s letter and our responsive letter are attached hereto.

Thanks, JM Zimmerman

Please note - I am unable to upload these documents - but am happy to forward them to anyone who would like to review them