Exhibit 2020-05-29 Cash email — Agent Fee Litigation (Dkt. 52.3)

Summary

Exhibit 3 is an email dated May 29, 2020 from Bill Cash of Levin, Papantonio, Thomas, Mitchell, Rafferty & Proctor, P.A., counsel for Sport & Wheat, with the subject line Sport & Wheat v. Synovus and ServisFirst. The email serves discovery requests and a deposition notice on Synovus Bank and copies counsel for ServisFirst, stating that she has accepted service of the amended complaint. It proposes a deposition of Synovus Bank on June 5, or during the week of June 8-12, conducted via Zoom, and a deposition of ServisFirst the same week. It also proposes a 26(f) conference early the following week, noting that the deadline to confer is June 17 and the plaintiff's expert report is due in mid-July, and asks the recipients to expedite responses.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

EXHIBIT 3
From: Bill Cash <bcash@levinlaw.com>
Date: May 29, 2020 at 4:20:30 PM EDT
To: "Nathanson, Paul J." <paul.nathanson@davispolk.com>
Cc: "John Wirt (jwirt@wirtlawfirm.com)" <jwirt@wirtlawfirm.com>, "Pam Wirt
(pcwirt@wirtlawfirm.com)" <pcwirt@wirtlawfirm.com>, Jim Butler <jim@butlerwooten.com>, Ramsey
Prather <Ramsey@butlerwooten.com>, "pbates@philipbates.net" <pbates@philipbates.net>, "Haynes,
Antonio M." <antonio.haynes@davispolk.com>, Becca Carneiro <bcarneiro@levinlaw.com>, Sara Anne
Ford <sford@lightfootlaw.com>
Subject: Sport & Wheat v. Synovus and ServisFirst


       Hello all,

       Service of discovery requests
       On behalf of Sport & Wheat, I am serving Synovus Bank with the
       attached discovery requests and deposition notice. I am also
       copying Sara Ford, who represents ServisFirst. Ms. Ford has
       accepted service of our amended complaint.

       Request for 30(b)(6) deposition
       Regarding the deposition of Synovus Bank: we would like to have
       this on June 5. I never just spring notices on people, but I wanted
       you to see the topics now. If that does not work, we are willing to
       go into the next week (June 8-12). Please tell us the physical
       location of the witness, but we expect to conduct the entire thing
       via Zoom. I will amend the notice once we have worked out the
       details.

       Sara, we would also like to have your client’s deposition during
       the week of June 8-12. The topics would be the same.

       Request for 26(f) conference
       I would like to set a 26(f) for early next week. Monday and
       Tuesday are generally open for me. I will throw out Tuesday at
       10am CDT—does that work?

       As you guys know, we are on a rocket docket with this case. The
       deadline to confer on 26(f) is June 17, and plaintiff’s expert report
       is due in the middle of July. Thus, we are asking you to expedite
       your responses and set these depositions as fast as possible. I am
       grateful for the help and will do what I can do repay the favor.
My personal cell number is 773-234-5605 and I am happy to talk
with any of you. Have a good weekend.


Bill Cash III
Shareholder

Levin, Papantonio, Thomas, Mitchell, Rafferty & Proctor, P.A.
316 South Baylen Street, Suite 600, Pensacola, Florida 32502
Phone: 850‐435‐7059
www.levinlaw.com


File and source

File

gov.uscourts.flnd.190491.52.3.pdf

Size

213,198 bytes

SHA-256

282fb386d98ae815701cb03bcbced5245561e0dbd24cf4cd0cd13a2735aa491f

Our copy

gov.uscourts.flnd.190491.52.3.pdf

Original

No public link identified.