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Original Message:

Re: Manhattan Club Lawsuit (by Gary P.):

A message Jean Zimmerman sent me on 11/11/19. He’s still active with the lawsuit!!

Good Morning,

The status conference in the Tucker case held on Wednesday, November 6, 2019 went very well.

The Court previously found in the decision it issued on September 19, 2019 that TMC failed to demonstrate that Mr. Tucker had an improper purpose either in 1) requesting the member list, or 2) in seeking to organize members for possible action by his counsel against TMC's management. To ensure that it has considered a complete record in deciding how to respond to Mr. Tucker's requests - including how any relief granted should be structured - the Court will allow TMC to depose Mr. Tucker to question him (including about his purpose in seeking the list) which will happen in the near future. However, this also gives Mr. Tucker the right to further investigate the bad intent and malfeasance by TMC's management.

The parties are scheduled to return to Court for a conference in January 2020 at which time more details as to a final resolution of Mr. Tucker's request should be available.

Thanks,

Jean-Marc Zimmerman Zimmerman Law Group 233 Watchung Fork Westfield, NJ 07090 T: (908) 768-6408 F: (908) 935-0751