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Re: Manhattan Club Lawsuit (by Jean-Marc Z.):

Good Evening,

I am writing to update you on our efforts to secure access to TMC’s member list and its books and records in the two actions pending in NY State Supreme Court.

In the Tucker v. TMC case, TMC’s counsel advised the Court during a hearing on April 3, 2019, after the Court demanded that TMC finally indicate the cost, that TMC would charge Mr. Tucker $10,000 to send a communication on his behalf to TMC members. Unfortunately, thereafter TMC refused to advise how many members it would be e-mailing and the cost per e-mail to do so, despite being asked by us several times to answer those two questions. Instead, TMC filed a motion last week to dismiss Mr. Tucker’s complaint, which we will vigorously oppose. Incidentally, we obtained a price quote from an independent vendor to send out 10,000 e-mails on behalf of Mr. Tucker for $1 not $10,000.

This past Friday we filed a reply brief in the Bodoh v. TMC case. Copies of those papers will soon be available for your review via a Dropbox link to be provided. Significantly, these papers refer to and cite portions of the Second Affirmation of Assistant NY State Attorney General (“NYAG”) Serwat Farooq filed in an action against TMC’s former Sponsor in 2014 that describes in great detail the NYAG’s findings regarding the deceitful and wrongful sales practices and conduct associated with the management and operation of TMC.

Messrs. Tucker and Bodoh are continuing their independent efforts to expose and investigate the serious wrongdoing at TMC.

We will keep you informed of future developments.

Thanks,

Jean-Marc Zimmerman Zimmerman Law Group 233 Watchung Fork, Westfield, NJ 07090 T: (908) 768-6408 F: (908) 935-0751 E: jmz@zimllp.com