Case 15-01193-abl Doc 144-10 Entered 04/07/17 10:04:43 Page 166 of 240

From: mlr@sandazza.com [jrrandazza.com1

Sent: Tuesday, August 07, 2012 3:13 PM
To: Stevan Ueberman
Subject: offer

Steve,

If Oron would like to wire us the $550,000 within 24 hours, we wW withdraw our motion
for lees.
And both parties agree that this dispute is 100% over between them.

If your client agrees to these general terms, then we will gladly come up with more specifics.
agreement Is to be Implied nor does it exist until we actually do settle on all terms of No
this particular
offer. This offer does not supersede any terms of the prior seWement. The only purpos
e of this overture
is to terminate the motion tot fees and any other possible disputes between the parties having
this litigation. Liberty Uoesnt bother Oron (or 8ochenko, or Pombb.oro. or torumophllla, to do with
etc.) and we put
each other in our rear view mirrors.

And, if Oron would like someone to show them how not to get sued in the future and would
like to have
some more of my play book, they are welcome to contact me directly, or through you.
I make a much
better friend than enemy.

DEFENDANT’S

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From: mjrcrandazza.com [mailto: mjr©randazzacoml

Sent: Tuesday, August 07, 2012 8:43 PM
To: Stevan Lieberman
Subject: Hong Kong

I just got a call from our HK counsel.

1) They spent $80K so far in USD. Liberty’s going to want a little more than $25K to satisfy them on
that. Do what you can.

2) It seems that we could get this resolved without filing anything in the USA except a joint notice to
release the paypal funds, if you want to get on the tel to your HK counsel and have the HK counsel
stipulate that say $650K in USD can be transferred from the HSBC account to our attorneys account in
Hong Kong.

3) Then, whatever you guy pay me to retain me would come from your paypal account, and would have
no real relevance to that. I spoke to my partner, who was adamant that we should earn $100K if we’re to
never be able to sue FF Magnat, Bochenko, Novafile.com, oron.com, etc. forever and ever- I got him to
go with $75K. But, for that, we’ll provide some really great value including a jurisdiction derailing plan
--

that you’ll drool over.

What do you think?

DEFENDANT’S
EXHIBIT
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From: mjr©randazza .com [mailto: mjr©randazza .com]

Sent: Tuesday, August 07, 2012 8:47 PM
To: Stevan Lieberman
Subject: Retainer

get this back to me asap. as soon as I get it back, P11 start moving everything else around.

DEFENDANT’S
EXHIBIT
1

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Arbitration Exhibit

368

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From: mjr@randazza.com [mailto:mjr@randazza.com]

Sent: Friday, August 10, 2012 5:16 PM
To: Val Gurvits
Subject: Re: Agreement foron)

ok. Write up the stip (I’m driving back from Phoenix).

We move $675,000.

I think we can deal with the other thing by saying the $75k is released to my trust for a settlement with me personally.
It’s not a retainer for services, but rather a settlement That might work.

Original Message
Subject:: Re: Agreement (oron)
From: VaI Gurvits &It;gurvits@bostonlawgroup.com>
Date: Aug 10, 2012 1:51 PM
To:: mjr@randazza.com” <mjr@randazza.com>
CC:

That works for Oron.

Va I
Sent from my iPhone

On Aug 10, 2012, at 11:16 AM, mjr@randazza.com <mjr@randazza.com> wrote:

> deposit funds with the court.

>
> Original Message
> Subject:: Re: Agreement foron)
> From: Val Gurvits &lt;gurvits@bostonlawgroup.com&gt;
> Date: Aug 9, 2012 6:43 PM
> To:: “mjr@randazza.com’ <mjr@randazza.com>
> CC:
>
>
> Nah. I am trying to tell you that you can trust ME. let me bat this issue around. I am sure we can agree on a work
around.
>
>

> Val DEFENDANT’S

> Sent from my iPhone EXHIBIT
1

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>
> On Aug 9, 2012, at 9:34 PM, mjr@randazza.com’ <mjr@ranclazza.com> wrote:
>
>> There isn’t the slightest chance that we will agree to be funds being put in your trust account.
>>

>> could agree that the funds may be deposited with the court. That way, the court will hold them until we feel that
we’ve gotten to a point where things are proper for disbursement.
>>
>> However, the amount must be a $550,000 plus any anticipated attorneys fees. I would say it should be the full
amount of our fees, with the remainder over and above anything that is really do to us in this first right back to your
trust account as soon as we wrap things up.
>>
>> Realistically, if the funds going to your trust account, I would bet my children’s lives that you would (for the right
amount of money) convert them into gold bars and deliver them to Moldova yourself.
>>
>> These guys fucked up. They made a deal, they fucked around, and now they want me to trust that putting the funds
into their attorney’s account will not present any difficulties?
>>
>> I appreciate that you entered into negotiations with me in order to buy them some time. I’m not sure what they were
doing with that time but every step of the way they have tried to screw us.
>>
>> First, we were trying to set up a mediation. However, during that time they were trying to explore options to file a
declaratory judgment action against us in Hong Kong or Germany.
>>
>> Then they made a settlement agreement which they refused to perform under.
>>
>> But now, after all that, I should trust them. Is that what you’re trying to tell me?
>>
>>
>>
>>
>>
>> Original Message
>> Subject:: RE: Agreement (oron)
>> From: Val Gurvits &lt;gurvits@bostonlawgroup.com&gt;
>> Date: Aug 9, 2012 5:28 PM
>> To:: “mjr@randazza.com” <mjr@randazza.com>
>> CC:
>>
>>
>> Yeah, but I am assuming that I can convince the court that the frozen funds constitute good bond, or I can get an
order releasing enough $ to place into a bond.
>>
>> Vat Gurvits
>> Boston Law Group, PC
>> 825 Beacon Street, Suite 20
>> Newton Centre, MA 02459
>> (617) 928-1804 direct
>> (617) 928-1800 main
>> f617) 928-1802 fax
>> vgurvits@ bostonlawgroup.com
>>

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>> -

>> The contents of this message and any attachments are

>> confidential and intended only for the addressee(s). This message may also be subject to attorney-client privilege. If
you received this message in error, please notify Boston Law Group, PC immediately and destroy the original message.
>>
>> Boston Law Group, PC
>> tel: 617/928-1800
>> e-mail: info@bostonlawgroup.com
>>
>> Original Message
>> From: mjr@randazza.com [mailto:mjr@randazza.comJ
>> Sent: Thursday, August 09, 2012 8:20 PM
>> To: Va! Gurvits
>> Subject: RE: Agreement (oron)
>>
>> A notice of appeal stays nothing without a bond, you know.
>>
>> Original Message
>> Subject:: RE: Agreement (oron)
>> From: Val Gurvits &lt;gurvits@bostonlawgroup.com&gt;
>> Date: Aug 9, 2012 4:28 PM
>> To:: ‘mjr@randazza.com” <mjt@randazza.com>
>> CC: “Evan Fray-Witzer” <Evan@CFWLegal.com>
>>
>> Marc,
>>
>> Here’s my current draft of the Settlement Agreement. Note that the payment terms of Section 1 reflect
that I hold
the escrowed funds which is not what and I discussed yesterday, but which Oron requested (lack of trust :). I put some
-

pretty stern conditions on my actions in that regard with which I hope you will be satisfied take a look.
-

>>
>> Although it goes without saying, this is only a working draft and no agreement will be in effect until it is signed
by
both parties.
>>
>> Lastly, I will likely have to file a Notice of Appeal in order to save Orons rights (given that it has to be filed within 10
days of the order). Will you agree not to enforce the execution while we are papering this. If you do agree, I can then
skip asking to stay the execution while the appeal is pending.
>>
>> Best,
>>
>> Vat Gurvits
>> Boston Law Group, PC
>> 825 Beacon Street, Suite 20
>> Newton Centre, MA 02459
>> (617) 928-1804 direct
>> (617) 928-1800 main
>> (617) 928-1802 fax
>> vgurvits@bostonlawgroup.com
>>
>>
The contents of this message and any attachments ate
>> confidential and intended only for the addressee(s). This message may also be subject to attorney-client privilege, If
you received this message in error, please notify Boston Law Group, PC immediately and destroy the original message.

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>>
>> Boston Law Group, PC
>> tel: 617/928-1800
>> e-mail: info@bostonlawgroup.com
>>
>> Original Message
>> From: mjr@randazza.com [mailto:mjr@randazza.com]
>> Sent: Thursday, August 09, 2012 6:44 PM
>> To: Val Gurvits
>> Subject: RE: Agreement (oron)
>>
>> Ok. I’m driving to Phoenix in a few hrs.
>>
>> Original Message
>> Subject:: RE: Agreement (oron)
>> From: Val Gurvits &lt;gurvits@bostonlawgroup.com&gt;
>> Date: Aug 9, 2012 2:57 PM
>> To:: “mjr@randazza.com’ <mjr@randazza.com
>>CC:
>>
>>
>> In the office working on it feverishly... (got sidetracked in court this morning on some unrelated bs).
>>
>> Val Gurvits
>> Boston Law Group, PC
>> 825 Beacon Street, Suite 20
>> Newton Centre, MA 02459
>> (617) 928-1804 direct
>> (617) 928-1800 main
>> (617) 928-1802 fax
>> vgurvits@bostonlawgroup.com
>>
>>
>> The contents of this message and any attachments are
>> confidential and intended only for the addressee(s). This message may also be subject to attorney-client privilege. If
you received this message in error, please notify Boston Law Group, PC immediately and destroy the original message.
>>
>> Boston Law Group, PC
>> tel: 617/928-1800
>> e-mail: info@bostonlawgroup.com
>>
>> Original Message
>> From: mjr@randazza.com [mailto:mjr@randazza.com]
>> Sent: Thursday, August 09, 2012 5:56 PM
>> To: Val Gurvits
>> Subject: Agreement (oron)
>>
>> Val, you have something for me? Day is getting old....
>>
>>
>>
>

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