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Original Message:

Re: Manhattan Club Lawsuit (by Janice F.):

I received email from Zimmerman. I would like to know who else is going to go with this before I pay him. Please let me know if you know of others who received this and are going to retain them.

Dear TMC Timeshare Owners: Based on our review and analysis of TMC documents including the bylaws, the survey results, and New York State and federal law, we have decided upon a legal strategy that we believe will, upon its termination, enable us to successfully obtain remedies, including a monetary recovery and avoidance of liability for maintenance fees for owners of TMC timeshare units. Specifically, we propose suing the Eichners and/or related entities and the existing TMC board (including the Eichner-appointed members) for a variety of causes of action, including, but not limited to: 1) breach of contract; 2) fraud; 3) civil RICO; 4) breach of fiduciary duty; and 5) violations of NY State's non-profit law. The case will not be a class action, but instead will be brought in the name of each of those timeshare owners who retain us. Our proposed action is separate from, and not precluded by, the NY State Attorney General’s settlement with the Eichners, which fails to adequately resolve the timeshare owners’ longstanding grievances. As the TMC timeshare is organized as a NY State not-for-profit corporation, we intend to challenge and replace the existing TMC entity and its board. We plan to liquidate the timeshare, condominium, and/or real estate holding by, for example, selling it outright to a buyer or having a new entity purchase the right to operate it. Regardless of the liquidation mechanism pursued, our intention is to enable you to receive a monetary recovery, release of liability for future maintenance and tax payments, and avoidance of net liability for past maintenance payments. There is, of course, no guarantee that the foregoing relief can be obtained in a particular case, especially with respect to past liabilities, as the ability to do so may depend on the particular facts of a timeshare owner’s personal circumstances. We are willing to represent you in the foregoing endeavor on a hybrid fee basis with an initial monetary payment, and a contingent percentage of any recovery we secure, on your behalf or more generally. Specifically (assuming we have sufficient interested clients), we will require an initial payment of $1,250 to retain us, and then 30% of any recovery we obtain from a settlement, liquidation and/or award of damages. Since we do not, and will not, represent all possible owners, we may take steps to seek recovery from TMC itself for the value of our services, but this will not increase your obligation, and may indeed increase both the amount and prospect for return of capital. Since we may represent or otherwise be aligned with a technically “adverse” party, such as a prospective buyer or broker to effectuate our plan, we will ask you to waive any potential conflict arising from such a scenario. Please contact us if you wish to retain us, and we will send you a formal retention agreement for execution. Thank you, JM Jean-Marc Zimmerman Zimmerman Law Group 233 Watchung Fork Westfield, NJ 07090 E: jmz@tmcsuit.com T: (908) 768-6408 F: (908) 935-0751 This communication constitutes an advertisement under the Rules of Professional Conduct governing the practice of lawyers. Our past results are no guarantee of future performance. Copyright © 2018 Zimmerman Law Group, All rights reserved. You are receiving this email because you requested additional information about potential solutions to Manhattan Club complaints.

Our mailing address is: Zimmerman Law Group 233 Watchung FrkWestfield, NJ 07090-3813

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