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1. March 5 - Pierce Demands Greenway Release the Ryan Defendants (Default

judgment was against Ecowin. Ryans were the remaining defendants. Allegedly
connected to the bad guys) (Pierce has a UCC with Steelstone LLC. It was in
existence for 6 months. Is run by two people with Israeli sounding names in
Brooklyn and, like Karish Kapital appears to be a residential address. This was also
double-pledging collateral.)

2. March 7 – UCC filings indicate Pravati declares $9.1 million default.

3. March 12 - Greenway sends PB damages support for default judgment,

including tax returns.

4. March 13 – Greenway unsuccessfully seeks damages update from Pierce.

5. March 25 – Greenway asks Pierce for damages calculation again.

6. March 25 – Pierce e-mail to client

From: John Pierce <jpierce@piercebainbridge.com>

Date: March 25, 2019 at 4:44:57 AM PDT

To: Gustavo <gescamilla@ymail.com>

Cc: Liza Haworth <azilcorp1@gmail.com>, Carolynn Beck

<cbeck@piercebainbridge.com>, PB Partners <partners@piercebainbridge.com>

Subject: Re: Ecowin1 uncontested motion default judgment

Carolynn or some partner you need to deal with this. I am closing massive deal this week .
Gus, litigation is a fluid process. It is intellectual combat. It is not conducted via CYA e-
mails. You need to stop. Candidly, I do not appreciate it in light of what I and this firm have
done for you after your threatening letter last year. And especially after what Jon Sorkowitz
has done for you.
 I assure you further threats will not receive such a warm response.

I have built and manage a global firm with 60 or 65 or 70 of the most elite litigators on the
planet that is still growing. I have been or will be in about 10 cities in two weeks or something
like that. I get thousands of emails a day and dozens of calls I am not in the mood for your ten
thousand-word e-mails with multiple fonts balded with underlines and italics. It is juvenile.

Team, someone jump on this and ensure we are handling this properly. I cannot be the person
dealing with default judgment prove-up hearings.

7. March 27 - Pierce requests already provided tax returns

8. March 27 – Greenway refuses to consent to releasing the Ryans.

9. March 27 – Pierce threatens client and says he is withdrawing.

"Didn't I tell you to stop threatening me/us and to leave me off your emails? I do not
"consent" to that. BTW, we will adhere to the ethical rules regardless of what you consent
to. We will not pursue claims against parties without merit.

We are withdrawing due to your lack of cooperation and other issues. CBI, cite the relevant
provisions of the engagement agreement. Until the withdrawal, we will continue to zealously
represent your interests as required to do under the ethical rules.

Now leave me alone until you force me to be deposed and testify at trial. Othereise, I do not
want to see you or hear your name even. This will not be a pleasant experience for you."

10. March 28 – Greenway responds and says Pierce message is

unacceptable. (The Steelstone UCC is terminated, suggesting Pierce got
money to pay it off.)

11. March 29 – Pierce files motion to withdraw.

12. April 1 – UCC’s indicate Pravati $9.1 million terminated.