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HomeMy WebLinkAboutExhibit D to Declaration of Tamara Crisp in Support of City of Renton's Opposition to Tracfone's Motion to Compel Audit FileEmail Issues, Explanations And Notes Time Stamp or Date on Doc Sheet Explanation of Issue 1. Tue, Dec 24, 2013 at 7:59 AM The following is listed below the email chain, but is not an attachment to it: City of Renton, Tax Recovery, and TF NDA - Sept. 2013.pdf    This attachment is listed in the previously submitted Email Attachments Chart, under the Sept. 26, 2013 time stamp. 2.Thu, Nov 7, 2013 at 4:20 PM Doc sheet says that we sent Mr. Cavalieri a list. Actually, we sent the date of another email that contained the list. 3. December 13, 2013 on Doc Sheet Error in Doc Sheet, said TracFone email was on December 13 but was actually on December 23. 4. December 24, 2013 on Doc Sheet Error on Doc Sheet, said TracFone wanted us to re-sign NDA; but Renton had signed the correct one. 5. July 28, 2014 Error on Doc sheet. Said the email was on July 28, it was actually on August 8. 6. September 24, 2014 The October 6, 2014 Update contains the phrase “After reviewing all of the information mentioned above, it does appear to us that TracFone does owe the utility tax to the City of Renton.” There was an error in indentation. The phrase was not as indented as the quote above it, but should not have been indented at all because it was commentary, not quote. Looking at the pages previous to this one (page 8), it becomes apparent that the email is not quoted in it’s entirety at all, but quoted partially, interspersed with commentary. The Doc sheet (and the Update mentioned above, in commentary fashion, does quote the Renton code, but the Renton code was not quoted in the actual email. The Doc sheet does not say that the Renton code was in the email, only that “city codes” were quoted, which was true. This made sense in the larger context of all the extra business going on between TracFone and TRS, however, it may not seem to make sense when the Renton audit is viewed in singularity. The point being made was that city codes around Washington State are written to make clear that TracFone’s activity is taxable. 7. November 29, 2014 Doc sheet mentions “On November 19th, 29th and December 5th of 2014, TRS sent emails to Mr. Ford of TracFone and asked him how things were coming along with the information that we requested for the audit.” But the November 29th email is not in the record. 8. May 26, 2015 Doc sheet has the date wrong. This email quoted was on May 29th, as was the reply. 9. December 4, 2015 Doc sheet misdates a December 3, 2015 email, dating it instead on the 4 th. 10. June 13, 2016 Doc sheet misdates the June 17, 2016 email as being on June 13th 11. April 7, 2017 The email April 7, 2017 was included in the “Emails All” submittal, in chronological order, but the date stamp (shown below) was missing: Re: Net/Gross question and information for the City of Burien Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Fri, Apr 7, 2017 at 4:21 PM 12. May 11, 2017, third in a row A mistake was made on the Doc sheet when it mentions a third May 11, 2017 email that should not properly be part of the Renton audit. The City of Renton’s name does not appear. 13. May 16, 2017 Doc sheet misdates the May 16, 2016 email as being on May 15th.