Matthew Gluck

Open tasks (3)

Decisions (5)

• Settlement negotiation positions clarified
  Justin's side is at $760k, Chase (opposing) is at $250k. Gluck previously indicated willingness to settle at $550k and is now proposing to counter at $625k, roughly halfway to the midpoint of $505k.
  Apr 19, 04:42 AM
• Proposed briefing sequence: Mosser files first, opposing counsel responds
  Mia Blackler proposes that Mosser's side file briefing first on the 6 upcoming motions, after which Lubin Olson can review new materials and respond, with the goal of avoiding further depositions. This is offered as a suggestion pending agreement.
  Apr 19, 04:40 AM
• Use of Sato Declaration in response to Receiver's motion
  A draft declaration for Justin Sato attaching M20 Invoice work product, CCSF Demand Letters, closing statement, and recorded liens will be used in connection with the response to the Receiver's motion.
  Apr 7, 12:00 AM
• Use of revised declaration in response to Receiver's motion
  Matthew Gluck sent Justin a revised draft declaration to be used with responses to the Receiver's motion, incorporating details about property tax payment obligations and recorded documents supporting closing statement charges.
  Apr 7, 12:00 AM
• No new work product for state lien backup argument
  Gluck indicated there is no point creating additional work product for the state liens backup argument given it already has known holes; existing support for individual payments is sufficient.
  Apr 6, 12:00 AM