Matthew Gluck

person· lfi

canonical email

mgluck@gluckdaniel.com

tenant

lfi

type

person

created

Apr 19, 04:45 AM

aliases

Matt, Matt Gluck, Matthew J. Gluck, Matthew Gluck

Likely duplicates (6) — candidates to merge

title	priority	due	status
Send closing statement to Matt for review	0.8	—	open
Obtain the cash allocation spreadsheet from Matt Gluck in Excel format	0.75	—	open
Review draft RFA/FROG 17.1 responses attached by Matt Gluck	0.7	—	open
Review draft RFA/FROG 17.1 responses attached by Matt Gluck	0.7	—	open
Schedule time with Matt Gluck next week to discuss feedback on discovery responses	0.7	—	open
Forward IRS letter to Matt re: estate tax payment demand	0.7	—	open
Schedule time with Matt to discuss feedback on draft discovery responses next week	0.7	—	open

Put Neveo up for deposition Friday then pursue evidentiary stipulation
Decided to have Neveo deposed on Friday and then push for a stipulation that his testimony applies across all matters, to counter Chase's building-by-building deposition strategy
Apr 1, 12:00 AM
Use declaration approach as alternative to repeated depositions
Agreed to draft a declaration and send it unsigned to Chase's counsel to see if it is sufficient to stop further depositions
Apr 1, 12:00 AM
Exclude pre-receivership amounts (~$480K) from motion demand
Matt's position that it is not credible to ask the judge for amounts already identified as pre-receivership; those amounts are explicitly excluded
Apr 1, 12:00 AM
Send short message to Tidewater/Wraith stating Chase negotiations are underway
Matt held his drafted email due to concern about inviting questions; group agreed on a short message without mentioning specific Chase outreach details
Apr 1, 12:00 AM
Present $760K settlement offer to Chase as negotiating position
The group agreed to convey $760K to Chase's counsel as the opening negotiating position, anticipating a counter in the threes or low fours
Apr 1, 12:00 AM

when	source	preview
Apr 19, 10:03 PM	m365-lfi	RE: Lockbox
Apr 19, 10:03 PM	m365-lfi	RE: Next Steps
Apr 19, 10:03 PM	m365-lfi	Re: FW: Next Steps
Apr 19, 09:48 PM	m365-lfi	RE: Receiver Cash
Apr 19, 08:52 PM	granola	Chase Check-in Call
Apr 19, 08:52 PM	granola	Mosser Zoom (Chase Negotiation)
Apr 19, 05:27 AM	outlook-contacts	Chief Operating Officer
Apr 19, 04:39 AM	m365-lfi	Fwd: Proposal
Apr 19, 04:39 AM	m365-lfi	Re: JPMC/Mosser - Sato depos on the other properties
Apr 19, 04:39 AM	m365-lfi	RE: Proposed Sato Declaration