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Re: Manhattan Club Lawsuit (by Margo R.):

ANOTHER UPDATE FROM ZIMMERMAN LAW GROUP

Mr. Zimmerman continues to work tirelessly on our behalf - see below - please let me know if you would like these documents e-mailed to you

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Good Evening,

We are writing to provide another update regarding our ongoing efforts to inspect TMC’s books and records. As recently indicated, TMC is strenuously fighting these efforts.

These efforts include an action we filed on behalf of David Bodoh in New York State Supreme Court last November to inspect TMC’s member list and its books and records.

In an opinion issued on January 31, 2019, Judge Kotler denied Mr. Bodoh’s inspection requests and dismissed his action. However, in doing so, we believe the Court erroneously overlooked or misapprehended certain facts and law - including allegations of wronging by TMC and BlueGreen – that warrant him being granted the right to inspect he requested.

Consequently, earlier this week we filed the following papers (copies attached hereto) to Renew and Reargue his case:

1. Notice of Motion to Renew and Reargue;

2. Affidavit of Jean-Marc Zimmerman;

3. Exhibits 1-10 to Zimmerman Affidavit;

4. Memorandum of Law; and

5. Proposed Order.

We will keep you apprised of developments in connection with our Motion.

Thanks,

JM Zimmerman

Zimmerman Law Group T: (908) 768-6408 F: (908) 935-0751 E: jmz@tmcsuit.com