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EXHIBIT 2
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 1 of 8
DWAYNE A. ROBINSON, ESQ. | P A R T N E R
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.377.0659 | Email drobinson@kttlaw.com
Firm Bio | Personal LinkedIn | Facebook | KTT LinkedIn
CAUTION: [This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the content
is safe.]
From:
Dwayne Robinson
To:
Lombardi, Stuart
Cc:
Cheney, Alexander; Levy, Joshua S.
Subject:
RE: Benworth/Womply
Date:
Thursday, June 13, 2024 10:03:45 AM
Attachments:
image001.png
*** EXTERNAL EMAIL ***
Stuart,
We received the package. Thank you. As you can imagine, we will need some time to review.
Best,
Dwayne
From: Lombardi, Stuart <slombardi@willkie.com>
Sent: Wednesday, June 12, 2024 3:15 PM
To: Dwayne Robinson <drobinson@kttlaw.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: RE: Benworth/Womply
Dwayne,
FedEx reports that it delivered the package to you today. It contains a USB disk with copies of loan
files for the loans Benworth identified in the spreadsheet we received from you on May 20, 2024.
Can you confirm that you received the USB disk and are able to access the files?
Womply believes it has now transmitted electronic copies of all of Benworth’s borrowers’ loan files,
as required by Arbitrator Brainerd’s Final Award dated May 30, 2024 (which was released
yesterday). Of course, if you identify any loan files that you believe are missing, please let us know
and we will work with you to investigate.
Thank you.
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 2 of 8
Regards,
Stuart
Stuart R. Lombardi
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 8882 | Fax: +1 212 728 8111
slombardi@willkie.com | vCard | www.willkie.com bio
From: Lombardi, Stuart <slombardi@willkie.com>
Sent: Tuesday, June 11, 2024 6:14 PM
To: 'Dwayne Robinson' <drobinson@kttlaw.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: RE: Benworth/Womply
Dwayne,
Womply shipped the loan files on a USB disk today via overnight FedEx. Here is the tracking
information:
Tracking number: 275795460146
Tracking link: https://www.fedex.com/fedextrack/?
trknbr=275795460146&trkqual=2460473000~275795460146~FX
Regards,
Stuart
Stuart R. Lombardi
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 8882 | Fax: +1 212 728 8111
slombardi@willkie.com | vCard | www.willkie.com bio
From: Dwayne Robinson <drobinson@kttlaw.com>
Sent: Tuesday, June 11, 2024 2:47 PM
To: Lombardi, Stuart <slombardi@willkie.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: Re: Benworth/Womply
*** EXTERNAL EMAIL ***
Hi Stuart,
Has this been sent out? Can you forward us the tracking info so we can been on the lookout?
Best,
Dwayne
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 3 of 8
CAUTION: [This email originated from outside of the organization. Do not click links or
open attachments unless you recognize the sender and know the content is safe.]
DWAYNE A. ROBINSON, ESQ. | P A R T N E R
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.377.0659 | Email drobinson@kttlaw.com
Firm Bio | Personal LinkedIn | Facebook | KTT LinkedIn
From: Lombardi, Stuart <slombardi@willkie.com>
Sent: Friday, June 7, 2024 6:05:42 PM
To: Dwayne Robinson <drobinson@kttlaw.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: Re: Benworth/Womply
Will do. Thank you.
On June 7, 2024 at 6:01:26 PM EDT, Dwayne Robinson <drobinson@kttlaw.com> wrote:
*** EXTERNAL EMAIL ***
Stuart,
Send it to me at my office in Coral Gables:
Kozyak Tropin & Throckmorton
Attention: Dwayne Robinson
2525 Ponce de Leon Boulevard, Floor 9
Coral Gables, Florida 33134
Best,
Dwayne
DWAYNE A. ROBINSON, ESQ. | P A R T N E R
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.377.0659 | Email drobinson@kttlaw.com
Firm Bio | Personal LinkedIn | Facebook | KTT LinkedIn
Stuart R. Lombardi
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 8882 | Fax: +1 212 728 8111
slombardi@willkie.com | vCard | www.willkie.com bio
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 4 of 8
CAUTION: [This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the content is
safe.]
From: Lombardi, Stuart <slombardi@willkie.com>
Sent: Friday, June 7, 2024 5:19:15 PM
To: Dwayne Robinson <drobinson@kttlaw.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: RE: Benworth/Womply
Dwayne,
It turns out that the files are too voluminous to practically FTP. Womply is putting them on
physical media to mail to you as soon as possible. Should we mail it to you at your office
address?
Regards,
Stuart
Stuart R. Lombardi
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 8882 | Fax: +1 212 728 8111
slombardi@willkie.com | vCard | www.willkie.com bio
From: Dwayne Robinson <drobinson@kttlaw.com>
Sent: Wednesday, June 5, 2024 3:48 PM
To: Lombardi, Stuart <slombardi@willkie.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: Re: Benworth/Womply
*** EXTERNAL EMAIL ***
Hi Stuart,
Any updates?
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 5 of 8
DWAYNE A. ROBINSON, ESQ. | P A R T N E R
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.377.0659 | Email drobinson@kttlaw.com
Firm Bio | Personal LinkedIn | Facebook | KTT LinkedIn
From: Dwayne Robinson <drobinson@kttlaw.com>
Sent: Friday, May 31, 2024 9:43:54 AM
To: Lombardi, Stuart <slombardi@willkie.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Subject: Re: Benworth/Womply
Good morning, Stuart,
Yes, please send it to me.
All the best,
Dwayne
DWAYNE A. ROBINSON, ESQ. | P A R T N E R
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.377.0659 | Email drobinson@kttlaw.com
Firm Bio | Personal LinkedIn | Facebook | KTT LinkedIn
From: Lombardi, Stuart <slombardi@willkie.com>
Sent: Friday, May 31, 2024 9:17:23 AM
To: Dwayne Robinson <drobinson@kttlaw.com>
Cc: Cheney, Alexander <ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 6 of 8
CAUTION: [This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the content is
safe.]
Subject: Benworth/Womply
Dwayne,
I hope you had a nice holiday weekend. Womply has gathered the loan files for
Benworth’s loans. Can we send them to you via FTP? That would be the fastest. If
yes, please let us know who we should direct the FTP to.
Thank you.
Regards,
Stuart
Stuart R. Lombardi
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 8882 | Fax: +1 212 728 8111
slombardi@willkie.com | vCard | www.willkie.com bio
Important Notice: This email message is intended to be received only by persons entitled to
receive the confidential information it may contain. Email messages to clients of Willkie Farr &
Gallagher LLP presumptively contain information that is confidential and legally privileged; email
messages to non-clients are normally confidential and may also be legally privileged. Please do
not read, copy, forward or store this message unless you are an intended recipient of it. If you
have received this message in error, please forward it back. Willkie Farr & Gallagher LLP is a
limited liability partnership organized in the United States under the laws of the State of
Delaware, which laws limit the personal liability of partners.
Important Notice: This email message is intended to be received only by persons entitled to
receive the confidential information it may contain. Email messages to clients of Willkie Farr &
Gallagher LLP presumptively contain information that is confidential and legally privileged; email
messages to non-clients are normally confidential and may also be legally privileged. Please do
not read, copy, forward or store this message unless you are an intended recipient of it. If you
have received this message in error, please forward it back. Willkie Farr & Gallagher LLP is a
limited liability partnership organized in the United States under the laws of the State of
Delaware, which laws limit the personal liability of partners.
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 7 of 8
Important Notice: This email message is intended to be received only by persons entitled to receive the
confidential information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP
presumptively contain information that is confidential and legally privileged; email messages to non-
clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or
store this message unless you are an intended recipient of it. If you have received this message in error,
please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership organized in the
United States under the laws of the State of Delaware, which laws limit the personal liability of partners.
Important Notice: This email message is intended to be received only by persons entitled to receive the
confidential information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP
presumptively contain information that is confidential and legally privileged; email messages to non-
clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or
store this message unless you are an intended recipient of it. If you have received this message in error,
please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership organized in the
United States under the laws of the State of Delaware, which laws limit the personal liability of partners.
Case 3:23-cv-01034-GMM Document 140-3 Filed 07/24/24 Page 8 of 8