HomeMy WebLinkAboutExhibit B to Declaration of Tamara Crisp in Support of City of Renton's Opposition to Tracfone's Motion to Compel Audit FileFrom: TRS <crisp@trs-integrity.com>
Sent: Friday, January 22, 2021 3:23 PM
To: Grant Degginger <deggingerg@lanepowell.com>; Scott M. Edwards
<edwardss@lanepowell.com>
Cc: Kari L. Sand <ksand@omwlaw.com>
Subject: In Reply to Your Requests
Hi Grant,
Thank you so much for putting your requests in writing; it makes us able to
move forward and fulfill your requests in a much more thorough and timely
way.
Regarding the schedules, hopefully the following will be helpful to you:
ExcelPrelim3Renton Tracfone.xls goes with the email that has
the timestamp Thu, Aug 10, 2017 at 12:27 PM. No other
ExcelPrelim3Renton Tracfone.xls spreadsheets were sent in
the email trail between TracFone and TRS. Since there are
apparently multiple spreadsheets with this name, the proper
one shows interest in the amount of $114,308.43. It will show
50% for May 2013 denoting interest that is calculated through
the end of August 2017. This one is in Batch 5, in the
Miscellaneous file, under the name "Attachments to emails
between TRS and TracFone 2."
There is a second ExcelPrelim3Renton
Tracfone.xls spreadsheet uploaded in the 5th Batch, outside of
the subfolder, that has the same interest amount, calculated
from through the same month: No change between these two.
I am guessing that, in another batch, Renton provided an
attachment named ExcelPrelim3Renton Tracfone.xls because
it was an attachment to an email from TRS to Renton. You will
be able to see on the date stamp for the email that the interest
update was done in early October 2019. Renton had requested
that TRS send them a copy with updated interest, and
unfortunately TRS neglected to change the name at that point.
This interest amount is $152,556.67, the same as the
spreadsheet with the clarifying AA name I speak of below.
Regarding the schedules including the suffixes A and AA, as
you may recall from my second deposition, we created, for
clarity, the spreadsheets below in order to be able to
have unique designations for spreadsheets that differ:
ExcelPrelim3Renton TracFoneA.xls has interest of
$142,259.04, using 69% for May 2013, denoting interest that is
calculated through the month of March 2019. I believe this is
the spreadsheet sent out in hardcopy with the assessment.
ExcelPrelim3Renton TracFone (higher interest)AA.xls, with
interest of $152,556.67, using 76% for May 2013 denoting
interest that is calculated through the month of October 2019. I
believe this is the spreadsheet (though renamed) that was
requested by Renton, but never sent to TracFone.
In response to the question regarding the dates the schedules were
created, all three of the above spreadsheets have creation dates early to
mid-fall of 2020. The reasons for this are mentioned above. When we
changed the interest on the spreadsheet, it was saved without changing
the name, and this copied over the earlier spreadsheet. Then, when we
became aware of the confusion this caused, we began downloading the
earlier spreadsheets that had actually been sent out by email (sent August
10, 2017, and on October 15, 2019), and renamed the one that matched
our assessment letter, giving it the suffix A. These processes improved the
naming convention, but gave the creation date for each to be in the fall of
2020.
You can get an approximate idea of the dates for these spreadsheets by
looking at the months of interest charged, and the date stamps of any
emails involved.
We have also included two attachments. One is a PDF named, because I
started work on it on the 17th, "TracFone TRS Renton More Emails 1-17-
21.pdf". It is a PDF of all of the emails I found that were left out of the
already submitted "TracFone TRS Renton Audit Emails All.doc." None had
attachments. In all but one of these, I was able to do the redacting in the
manner you requested without unnecessarily revealing inappropriately
other business.
The other attachment is a table of "Email Issues, Explanations and Notes."
This table was made as I looked over the Documentation Sheet (ie the
updates combined) very carefully to see if there were emails referenced
that were mis-dated, or had some other issue which might have led to
confusion if it was not cleared up.
If you have questions or issues regarding any of these submittals, please
contact me and CC Kari Sand.
Sincerely,
Tamara
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