[08-10-21] declaration of l. londell mcmillan in support

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STATE OF MINNESOTA DISTRICT COURT COUNTY OF CARVER FIRST JUDICIAL DISTRICT PROBATE DIVISION In Re: The Estate of Prince Rogers Nelson, Decedent. Case Type: Special Administration Court File No: 10-PR-16-46 Judge: Kevin W. Eide DECLARATION OF L. LONDELL MCMILLAN IN SUPPORT OF MOTION TO ENFORCE EXISTING COURT ORDERED PROTOCOLS ON COMMUNICATIONS AND ESTABLISH PROTOCOLS ON COMMUNICATIONS TO FUTURE TRANSITION L. Londell McMillan hereby states and declares as follows: 1. This declaration and attached exhibits are submitted in support of the SNJ, L. Londell McMillan and Charles Spicer’s Motion to Enforce Existing Court Ordered Protocols on Communications and Establish Protocols on Communications to Future Transition dated August 10, 2021. 2. Attached hereto as Exhibit A is a true and correct copy of an email chain between L. Londell McMillan, Andrea Bruce and Angela Aycock, dated August 3, 2021. 3. Attached hereto as Exhibit B is a true and correct copy of an email chain between L. Londell McMillan, Andrea Bruce and Joseph Cassioppi dated August 3, 2021. 4. Attached hereto as Exhibit C and filed under seal is a true and correct copy of an email chain between L. Londell McMillan, Larry Mestel and Joseph Cassioppi dated May 25, 2021. 5. Attached hereto as Exhibit D and filed under seal is a true and correct copy of an email from L. to Judge Gilbert and other interested parties dated May 27, 2021. 10-PR-16-46 Filed in District Court State of Minnesota 8/10/2021 4:58 PM

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Page 1: [08-10-21] Declaration of L. Londell McMillan in Support

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF CARVER FIRST JUDICIAL DISTRICT PROBATE DIVISION

In Re:

The Estate of Prince Rogers Nelson,

Decedent.

Case Type: Special Administration Court File No: 10-PR-16-46

Judge: Kevin W. Eide

DECLARATION OF L. LONDELL MCMILLAN IN SUPPORT OF

MOTION TO ENFORCE EXISTING COURT ORDERED PROTOCOLS ON

COMMUNICATIONS AND ESTABLISH PROTOCOLS ON COMMUNICATIONS

TO FUTURE TRANSITION

L. Londell McMillan hereby states and declares as follows:

1. This declaration and attached exhibits are submitted in support of the SNJ, L.

Londell McMillan and Charles Spicer’s Motion to Enforce Existing Court Ordered Protocols on

Communications and Establish Protocols on Communications to Future Transition dated August

10, 2021.

2. Attached hereto as Exhibit A is a true and correct copy of an email chain between

L. Londell McMillan, Andrea Bruce and Angela Aycock, dated August 3, 2021.

3. Attached hereto as Exhibit B is a true and correct copy of an email chain between

L. Londell McMillan, Andrea Bruce and Joseph Cassioppi dated August 3, 2021.

4. Attached hereto as Exhibit C and filed under seal is a true and correct copy of an

email chain between L. Londell McMillan, Larry Mestel and Joseph Cassioppi dated May 25,

2021.

5. Attached hereto as Exhibit D and filed under seal is a true and correct copy of an

email from L. to Judge Gilbert and other interested parties dated May 27, 2021.

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 2: [08-10-21] Declaration of L. Londell McMillan in Support

2

I declare under penalty of perjury that everything I have stated in this document is true and

correct.

Signed on August 10, 2021 in the State of New York, County of New York.

/s/ L. Londell McMillan L. Londell McMillan

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 3: [08-10-21] Declaration of L. Londell McMillan in Support

EXHIBIT A to

Declaration of L. Londell McMillian (August 10, 2021)

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 4: [08-10-21] Declaration of L. Londell McMillan in Support

https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1707110496665409704%7Cmsg-f%3A1707110496665409704&sim… 1/4

---------- Forwarded message --------- From: Aycock, Angela (Contingent Worker) <[email protected]> Date: Tue, Aug 3, 2021 at 2:45 PM Subject: RE: Heirs Meetings- Go Forward To: L Londell McMillan <[email protected]>, Bruce, Andrea <[email protected]> Cc: Charles Spicer, Jr. ([email protected]) <[email protected]>, [email protected] <[email protected]>, Justice James Gilbert<[email protected]>, Larry Mestel <[email protected]>, Norrine Nelson ([email protected]) <[email protected]>,President Nelson <[email protected]>, Ramon Villa <[email protected]>, Tyka Nelson <[email protected]>,Joseph Cassioppi ([email protected]) <[email protected]>

Hi Londell,

 

We believe it makes sense for the parties to utilize Justice Gilbert to assist us to work through these issues in Heirs Meetings/Communicationsprocess going forward.   We will communicate with Justice Gilbert regarding our position, with the goal of setting-up a mediation to discuss inthe near future.

 

Thank you,

 

 

Angela Aycock | Estate Administration

Comerica Bank / Comerica Bank & Trust, N.A. | MC 3316 | P.O. Box 75000 | Detroit, MI 48275-3316

Office Telephone: 302.252.3875

Mobile Telephone: 248.321.4057

*Please note new email address: [email protected]

 

 

From: L Londell McMillan <[email protected]> Sent: Tuesday, August 3, 2021 10:01 AM To: Bruce, Andrea <[email protected]> Cc: Charles Spicer, Jr. ([email protected]) <[email protected]>; [email protected]; Justice James Gilbert<[email protected]>; Larry Mestel <[email protected]>; Norrine Nelson ([email protected]) <[email protected]>;President Nelson <[email protected]>; Ramon Villa <[email protected]>; Tyka Nelson <[email protected]>;

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 5: [08-10-21] Declaration of L. Londell McMillan in Support

https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1707110496665409704%7Cmsg-f%3A1707110496665409704&sim… 2/4

Aycock, Angela (Contingent Worker) <[email protected]>; Joseph Cassioppi ([email protected]) <[email protected]> Subject: Re: Heirs Meetings- Go Forward

Hi Andrea, thank you for your reply. It was my understanding that this meeting covered a range of topics Comerica wanted to discuss and the heirswished to discuss. Am I incorrect here? Indeed, the prior email was not clear on what was going to be the topic of the meetings you wish to now makeevery other month. Can you explain?

Would you also be open, as a result of changing the current heirs and interested parties meetings, to having brief weekly transition planning meetings,starting this month? Presumably, there is a lot to cover. Do you agree?

Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Tue, Aug 3, 2021 at 9:46 AM Bruce, Andrea <[email protected]> wrote:

Hi Londell- for clarity, the meetings described below are not intended to be transition meetings. They are in lieu of the monthly heirs meetings. I wouldanticipate transition specific meetings would be separate from these and held as necessary.

Andrea Bruce, CFP® | Vice President, Manager- Trust Unique Assets |

Comerica Bank / Comerica Bank & Trust, N.A. | MC 2393 | 3551 Hamlin Rd | Auburn Hills, MI 48326

P: 248.371.6855 | F: 248.371.6739 | [email protected]

From: L Londell McMillan <[email protected]> Sent: Tuesday, August 3, 2021 9:39:38 AM To: Bruce, Andrea <[email protected]> Cc: Charles Spicer, Jr. ([email protected]) <[email protected]>; [email protected] <[email protected]>; Justice JamesGilbert <[email protected]>; Larry Mestel <[email protected]>; Norrine Nelson ([email protected])<[email protected]>; President Nelson <[email protected]>; Ramon Villa <[email protected]>; Tyka Nelson<[email protected]>; Aycock, Angela (Contingent Worker) <[email protected]>; Joseph Cassioppi([email protected]) <[email protected]> Subject: Re: Heirs Meetings- Go Forward

Good Morning Andrea:

Please be advised that SNJ, Charles and I are concerned with this approach and we would like to discuss it in detail or have you summarize yourrationale and insights here. As Comerica's administration of the Prince Estate should be winding down and transition preparation should be happeningto prepare the remaining heirs and interested parties, we need even more transition planning meetings with Comerica not less. There are numerousmatters that require explanation and simply communicating by email is not the best practice, as emails alone can often be misunderstood -- we do needboth. Accordingly, we wish to discuss this matter in a manner directed by the Court rather than Comerica, and F&B, unilaterally changing thecommunication protocols.

FYI, I have no particular objection to having F&B join the calls either, as that may be helpful to expedite some matters. We will see, however, there ismuch to discuss and do. Please let us know if you are available to discuss this matter today or tomorrow. We will make ourselves available at yourconvenience to mutually resolve this matter.

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 6: [08-10-21] Declaration of L. Londell McMillan in Support

https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1707110496665409704%7Cmsg-f%3A1707110496665409704&sim… 3/4

Thank you,

Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Mon, Aug 2, 2021 at 4:20 PM Bruce, Andrea <[email protected]> wrote:

Dear Heirs and Interested Par�es,

Given the current composi�on of the beneficial interest holders in the Estate, Comerica believes it is appropriate to ins�tute a changein the heirs mee�ngs structure. Specifically, we think it would be beneficial to pivot from one monthly mee�ng with the natural heirsand a separate monthly mee�ng with the interested par�es, to “all-hands” mee�ngs every other month. The “all-hands” mee�ngswould include Comerica, Primary Wave, Londell, Charles, the natural heirs who s�ll hold expectancy interests, heirs advisors /representa�ves, a representa�ve of Fredrikson & Byron, and counsel to the heirs and interested par�es if they desire to include legalcounsel.

Comerica would supplement the every other month mee�ngs with a monthly wri�en report similar in detail and topics as thehistorical heirs mee�ngs. In addi�on, we would con�nue to provide regular email updates around various ma�ers as they arise, as wehave been doing since our incep�on as Personal Representa�ve.

We will plan for the first of all hands mee�ngs for September 14th—keeping the �me that was already set aside for the heirs mee�ngthat month. I will update the invite to include the par�es that are not already on it. We will plan to issue our first monthly wri�en

report in Mid-August, and we will cancel the scheduled heirs mee�ng call for August 17th and the Interested Par�es mee�ng callsthat are scheduled for balance of the year.

If we receive a counteroffer from the IRS in the mean�me, we will schedule a mee�ng specific to that piece following receipt.

Please let us know if you have ques�ons or concerns about these changes.

Thank you,

Andrea Bruce, CFP® | Vice President, Manager- Trust Unique Assets | Comerica Trust

Comerica Bank / Comerica Bank & Trust, N.A. | MC 2393 | 3551 Hamlin Rd | Auburn Hills, MI 48326

P: 248.371.6855 | F: 248.371.6739 | [email protected]

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 7: [08-10-21] Declaration of L. Londell McMillan in Support

https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1707110496665409704%7Cmsg-f%3A1707110496665409704&sim… 4/4

Please be aware that if you reply directly to this particular message, your reply may not be secure. Do not use email to send us communications thatcontain unencrypted confidential information such as passwords, account numbers or Social Security numbers. If you must provide this type ofinformation, please visit comerica.com to submit a secure form using any of the ”Contact Us” forms. In addition, you should not send via email anyinquiry or request that may be time sensitive. The information in this e-mail is confidential. It is intended for the individual or entity to whom it isaddressed. If you have received this email in error, please destroy or delete the message and advise the sender of the error by return email.

Please be aware that if you reply directly to this particular message, your reply may not be secure. Do not use email to send us communications thatcontain unencrypted confidential information such as passwords, account numbers or Social Security numbers. If you must provide this type ofinformation, please visit comerica.com to submit a secure form using any of the ”Contact Us” forms. In addition, you should not send via email anyinquiry or request that may be time sensitive. The information in this e-mail is confidential. It is intended for the individual or entity to whom it isaddressed. If you have received this email in error, please destroy or delete the message and advise the sender of the error by return email.

Please be aware that if you reply directly to this particular message, your reply may not be secure. Do not use email to send us communications thatcontain unencrypted confidential information such as passwords, account numbers or Social Security numbers. If you must provide this type ofinformation, please visit comerica.com to submit a secure form using any of the ”Contact Us” forms. In addition, you should not send via email any inquiryor request that may be time sensitive. The information in this e-mail is confidential. It is intended for the individual or entity to whom it is addressed. If youhave received this email in error, please destroy or delete the message and advise the sender of the error by return email.

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 8: [08-10-21] Declaration of L. Londell McMillan in Support

EXHIBIT B to

Declaration of L. Londell McMillian (August 10, 2021)

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 9: [08-10-21] Declaration of L. Londell McMillan in Support

8/6/2021 NorthStar Business Enterprises Mail - Re: Heads Up - Press Release- Welcome 2 America

https://mail.google.com/mail/u/1?ik=1eb4bfd48a&view=pt&search=all&permthid=thread-f%3A1706999905152128003%7Cmsg-f%3A17071062918346… 1/5

Matthew Abbott <[email protected]>

Re: Heads Up - Press Release- Welcome 2 America 1 message

L Londell McMillan <[email protected]> Tue, Aug 3, 2021 at 4:43 PMTo: "Cassioppi, Joseph" <[email protected]>Cc: "Aycock, Angela (Contingent Worker)" <[email protected]>, Norrine Nelson <[email protected]>,"Charles F. Spicer Jr." <[email protected]>, "James H. Gilbert" <[email protected]>, "Alan I. Silver"<[email protected]>, Matthew Abbott <[email protected]>, "Bruce, Andrea" <[email protected]>

Joseph, we've grown tired of your pattern of false narratives and intentional provocation. My initial and uncontroversialemail simply asked "Is there a reason I am often excluded from certain of your emails?" It is a perfectly legitimate andnon-confrontational question.

Your comment that the "only activity that is unnecessarily driving up fees and costs in this matter is your insistence oncontesting substantially every action taken and decision made by Comerica" is unhelpful and an inaccurate distortion.Neither SNJ, Charles nor I contested anything on this email thread. I simply requested an explanation as to why Charlesand I seem to be excluded from receiving certain information, including yesterday's press release.

We are the ones disappointed and perplexed that you and Comerica are not following the Court's directives in regard todispute resolution. The Court has indicated that the parties should consult on disputed issues and only proceed tomediation if we have conferred and are unable to reach agreement. However, you and Comerica have, on severaloccasions, entirely refused to confer in good faith and instead forced the issues immediately into mediation, which givesrise to increased legal fees and mediation costs as well as substantial delays in resolving issues. Andrea's emailresponse yesterday is just the latest instance of this. This is a highly inefficient way to handle disputes, and moreimportantly, it is contrary to the Court's instructions that the parties are to confer and only resort to mediation when itbecomes absolutely necessary.

Ultimately we should all share the same goal here, which is to move the Estate toward closure. Indeed, some of us doubtyour and Comerica's desire to do so. Nonetheless, we would like to amicably resolve outstanding issues that the partiesmay disagree on, but it is impossible to accomplish this when you and Comerica refuse to engage directly, and insist oncommunicating entirely through an expensive and slow-moving mediation process. Mediation serves a purpose and mayultimately be necessary to resolve some of the remaining issues, but it should not be a first resort. Opening a directdialogue, consistent with the Court's directives, would serve to reduce some of the frustration and hopefully ease some ofthe tension that has developed.

Lastly, your personal insults towards me are neither effective nor helpful, and they unnecessarily cost the Estate moremoney for you to place such energy and time in framing these false and unsupported narratives. We seem to do betterwhen we communicate and speak rather than when you initiate or reply to emails. We invite that path of communicationin addition to merely sending emails.

Thank you,Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Mon, Aug 2, 2021 at 6:56 PM Cassioppi, Joseph <[email protected]> wrote:

Londell:

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 10: [08-10-21] Declaration of L. Londell McMillan in Support

8/6/2021 NorthStar Business Enterprises Mail - Re: Heads Up - Press Release- Welcome 2 America

https://mail.google.com/mail/u/1?ik=1eb4bfd48a&view=pt&search=all&permthid=thread-f%3A1706999905152128003%7Cmsg-f%3A17071062918346… 2/5

I have noticed a pattern where you evidently assume that the highly experienced and professional female trust officersat Comerica are incapable of drafting simple emails. That is unfortunate.

Comerica’s treatment of you, as the holder of a small portion, via assignment, of an expectancy interest in the Estate isidentical to how Comerica treated Primary Wave when it was in the same position. That treatment was approved bythe Court in early 2020 with respect to Primary Wave for the reason stated in Andrea’s email below. Nevertheless,Comerica has stated that it is willing to discuss the issue at mediation. If you are unwilling to engage in that process,then that is up to you.

Finally, the only activity that is unnecessarily driving up fees and costs in this matter is your insistence on contestingsubstantially every action taken and decision made by Comerica. Your insistence on disagreeing simply for the sake ofdisagreeing is disappointing and inconsistent with your representation, earlier this year, that you would help alleviateconflict related to the Estate. To date, your involvement has resulted in the exact opposite.

Sincerely,

Joseph J. Cassioppi | Fredrikson & Byron, P.A.

200 South Sixth Street, Suite 4000 | Minneapolis, Minnesota 55402

Direct: 612.492.7414 | Cell: 952.212.8972  | [email protected]

**This is a transmission from the law �irm of Fredrikson & Byron, P.A. and may contain information which is privileged, con�idential, and protected bythe attorney-client or attorney work product privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of thecontents of this message is prohibited. If you have received this transmission in error, please destroy it and notify us immediately at our telephonenumber (612) 492-7000. The name and biographical data provided above are for informational purposes only and are not intended to be a signature orother indication of an intent by the sender to authenticate the contents of this electronic message.**

From: L Londell McMillan <[email protected]> Sent: Monday, August 2, 2021 11:33 AM To: Bruce, Andrea <[email protected]> Cc: Aycock, Angela (Contingent Worker) <[email protected]>; sharon nelson <[email protected]>; NorrineNelson <[email protected]>; Charles F. Spicer Jr. <[email protected]>; James H. Gilbert<[email protected]>; Cassioppi, Joseph <[email protected]>; Alan I. Silver <[email protected]>;Aaron R. Thom <[email protected]>; Matthew Abbott <[email protected]> Subject: Re: Heads Up - Press Release- Welcome 2 America

[EXTERNAL E-MAIL]

Andrea, I presume this response was written or approved by Joseph Cassioppi (it sounds like him) so I am includinghim in this email.

What is the basis of your decision to differentiate on which interested parties gain more access to matters?

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

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8/6/2021 NorthStar Business Enterprises Mail - Re: Heads Up - Press Release- Welcome 2 America

https://mail.google.com/mail/u/1?ik=1eb4bfd48a&view=pt&search=all&permthid=thread-f%3A1706999905152128003%7Cmsg-f%3A17071062918346… 3/5

Is it your position that heirs who sold out their interests and Primary Wave who bought their interests all deserve morecommunication than Charles and I who not only have signed confidentiality NDAs but also we are interested parties?

You do know such discrimination on Comerica's part invites more legal court and mediation costs for the Estate?

You do know that the Court has not authorized any such differentiation correct?

Why does Comerica continue to invite these objections and costs?

It is very time consuming and offensive.

Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Mon, Aug 2, 2021 at 12:12 PM Bruce, Andrea <[email protected]> wrote:

Hi Londell,

The court has recognized that the siblings of Prince who are heirs have a heightened interest inunderstanding and being informed around ac�vity, legacy and crea�ve ma�ers, and as such they areprovided more informa�on than would be typically provided to heirs of an Estate. Now that PrimaryWave has acquired almost half of the beneficial interests in the Estate, we believe that it is appropriatethat they are included in the broader line of communica�ons as well, and we have s�pulated to that withthem given the magnitude of their interest. To the extent that you wish to discuss changes to infosharing with you based on your much smaller assignees interest in the Estate, we are happy to do so inour next mediated session with Jus�ce Gilbert.

Thank you,

Andrea Bruce, CFP® | Vice President, Manager- Trust Unique Assets | Comerica Trust

Comerica Bank / Comerica Bank & Trust, N.A. | MC 2393 | 3551 Hamlin Rd | Auburn Hills, MI 48326

P: 248.371.6855 | F: 248.371.6739 | [email protected]

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 12: [08-10-21] Declaration of L. Londell McMillan in Support

8/6/2021 NorthStar Business Enterprises Mail - Re: Heads Up - Press Release- Welcome 2 America

https://mail.google.com/mail/u/1?ik=1eb4bfd48a&view=pt&search=all&permthid=thread-f%3A1706999905152128003%7Cmsg-f%3A17071062918346… 4/5

From: L Londell McMillan <[email protected]> Sent: Friday, July 30, 2021 12:23 PM To: Bruce, Andrea <[email protected]> Cc: Aycock, Angela (Contingent Worker) <[email protected]>; sharon nelson <[email protected]>;Norrine Nelson <[email protected]>; Charles F. Spicer Jr. <[email protected]>; James H. Gilbert<[email protected]>; Cassioppi, Joseph <[email protected]>; Alan I. Silver <[email protected]>;Aaron R. Thom <[email protected]> Subject: Re: Heads Up - Press Release- Welcome 2 America

Hello Andrea, I was forwarded this email from Sharon. Is there a reason I am often excluded from certain of youremails?

Please advise. Thank you.

Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Fri, Jul 30, 2021 at 12:15 PM Sharon Nelson <[email protected]> wrote:

From Sharon

Sent from my iPhone

Begin forwarded message:

From: "Bruce, Andrea" <[email protected]> Date: July 30, 2021 at 8:50:32 AM CDT To: "Charles Spicer, Jr. ([email protected])" <[email protected]>,"[email protected]" <[email protected]>, Justice James Gilbert<[email protected]>, Larry Mestel <[email protected]>, "Norrine Nelson([email protected])" <[email protected]>, "President Nelson "<[email protected]>, Ramon Villa <[email protected]>, Tyka Nelson<[email protected]> Cc: "Aycock, Angela (Contingent Worker)" <[email protected]> Subject: Heads Up - Press Release- Welcome 2 America

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

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8/6/2021 NorthStar Business Enterprises Mail - Re: Heads Up - Press Release- Welcome 2 America

https://mail.google.com/mail/u/1?ik=1eb4bfd48a&view=pt&search=all&permthid=thread-f%3A1706999905152128003%7Cmsg-f%3A17071062918346… 5/5

Please find a�ached a Welcome 2 America press release that is going out today. Thanks.

Andrea Bruce, CFP® | Vice President, Manager- Trust Unique Assets | Comerica Trust

Comerica Bank / Comerica Bank & Trust, N.A. | MC 2393 | 3551 Hamlin Rd | Auburn Hills, MI48326

P: 248.371.6855 | F: 248.371.6739 | [email protected]

Please be aware that if you reply directly to this particular message, your reply may not be secure.Do not use email to send us communications that contain unencrypted confidential information suchas passwords, account numbers or Social Security numbers. If you must provide this type ofinformation, please visit comerica.com to submit a secure form using any of the ”Contact Us” forms.In addition, you should not send via email any inquiry or request that may be time sensitive. Theinformation in this e-mail is confidential. It is intended for the individual or entity to whom it isaddressed. If you have received this email in error, please destroy or delete the message andadvise the sender of the error by return email.

Please be aware that if you reply directly to this particular message, your reply may not be secure. Do not use emailto send us communications that contain unencrypted confidential information such as passwords, account numbersor Social Security numbers. If you must provide this type of information, please visit comerica.com to submit asecure form using any of the ”Contact Us” forms. In addition, you should not send via email any inquiry or requestthat may be time sensitive. The information in this e-mail is confidential. It is intended for the individual or entity towhom it is addressed. If you have received this email in error, please destroy or delete the message and advise thesender of the error by return email.

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

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REDACTED EXHIBIT C to

Declaration of L. Londell McMillian (August 10, 2021)

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

Page 15: [08-10-21] Declaration of L. Londell McMillan in Support

https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1700821131344018707%7Cmsg-f%3A1700821131344018707&sim… 1/6

---------- Forwarded message --------- From: L Londell McMillan <[email protected]> Date: Tue, May 25, 2021 at 1:45 PM Subject: Re: transiton To: Cassioppi, Joseph <[email protected]> Cc: Larry Mestel <[email protected]>, [email protected] <[email protected]>, Omarr Baker <[email protected]>,Jonas Herbsman <[email protected]>, Tyka Nelson <[email protected]>, President Nelson <[email protected]>,Sharon Nelson <[email protected]>, [email protected] <[email protected]>, Ramon Villa <[email protected]>, Justice JamesGilbert ([email protected]) <[email protected]>, Alan I. Silver <[email protected]>, J. Magnuson Eric([email protected]) <[email protected]>, [email protected] <[email protected]>, Bruce, Andrea<[email protected]>, Aycock, Angela (Contingent Worker) <[email protected]>, Greiner, Mark <[email protected]>,<[email protected]>

Joseph,

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM

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https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1700821131344018707%7Cmsg-f%3A1700821131344018707&sim… 2/6

Sincerely,

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Mon, May 24, 2021 at 8:45 PM Cassioppi, Joseph <[email protected]> wrote:

Rule 408 Settlement/Mediation Communication

Good evening everyone:

Regards,

Joseph J. Cassioppi | Fredrikson & Byron, P.A.

200 South Sixth Street, Suite 4000 | Minneapolis, Minnesota 55402

Direct: 612.492.7414 | Cell: 952.212.8972  | [email protected]

**This is a transmission from the law �irm of Fredrikson & Byron, P.A. and may contain information which is privileged, con�idential, and protected by the attorney-client or attorney workproduct privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in error,please destroy it and notify us immediately at our telephone number (612) 492-7000. The name and biographical data provided above are for informational purposes only and are not intendedto be a signature or other indication of an intent by the sender to authenticate the contents of this electronic message.**

From: L Londell McMillan <[email protected]> Sent: Wednesday, May 19, 2021 6:38 PM To: Cassioppi, Joseph <[email protected]> Cc: Larry Mestel <[email protected]>; Bruce, Andrea <[email protected]>; Aycock, Angela (Contingent Worker)<[email protected]>; [email protected]; Omarr Baker <[email protected]>; Jonas Herbsman <[email protected]>; TykaNelson <[email protected]>; President Nelson <[email protected]>; Sharon Nelson <[email protected]>;

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[email protected]; Ramon Villa <[email protected]>; Justice James Gilbert ([email protected]) <[email protected]>;Greiner, Mark <[email protected]>; Alan I. Silver <[email protected]>; Matthew Abbott <[email protected]>; J. Magnuson Eric([email protected]) <[email protected]> Subject: Re: transiton

[EXTERNAL E-MAIL]

Joseph (on behalf of Comerica):

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Thank you kindly.

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Wed, May 19, 2021 at 11:12 AM Cassioppi, Joseph <[email protected]> wrote:

Larry & Londell:

Regards,

Joseph J. Cassioppi | Fredrikson & Byron, P.A.

200 South Sixth Street, Suite 4000 | Minneapolis, Minnesota 55402

Direct: 612.492.7414 | Cell: 952.212.8972  | [email protected]

**This is a transmission from the law �irm of Fredrikson & Byron, P.A. and may contain information which is privileged, con�idential, and protected by the attorney-client or attorney work

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https://mail.google.com/mail/u/0?ik=c7d387b4db&view=pt&search=all&permthid=thread-f%3A1700821131344018707%7Cmsg-f%3A1700821131344018707&sim… 5/6

product privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission inerror, please destroy it and notify us immediately at our telephone number (612) 492-7000. The name and biographical data provided above are for informational purposes only and are notintended to be a signature or other indication of an intent by the sender to authenticate the contents of this electronic message.**

From: L Londell McMillan <[email protected]> Sent: Tuesday, May 18, 2021 3:15 PM To: Larry Mestel <[email protected]> Cc: Bruce, Andrea <[email protected]>; Aycock, Angela (Contingent Worker) <[email protected]>; [email protected]; OmarrBaker <[email protected]>; Jonas Herbsman <[email protected]>; Tyka Nelson <[email protected]>; PresidentNelson <[email protected]>; Sharon Nelson <[email protected]>; [email protected]; Ramon Villa <[email protected]>;Justice James Gilbert ([email protected]) <[email protected]>; Cassioppi, Joseph <[email protected]>; Greiner, Mark<[email protected]> Subject: Re: transiton

[EXTERNAL E-MAIL]

Hello Andrea and Larry,

Thank you,

Londell

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

On Tue, May 18, 2021 at 3:01 PM Larry Mestel <[email protected]> wrote:

Andrea/Angela,

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LM

Lawrence Mestel | Chief Executive Officer and Founder

116 E 16th Street – Floor 9 | New York, NY |  10003 |  

Office (212) 584-8080 Cell (917) 287-8586  [email protected]  

PrimaryWave.com

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REDACTED EXHIBIT D to

Declaration of L. Londell McMillian (August 10, 2021)

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---------- Forwarded message --------- From: L Londell McMillan <[email protected]> Date: Thu, May 27, 2021 at 1:59 PM Subject: PRN ESTATE: MEDIATION STATEMENT To: James H. Gilbert <[email protected]>, Nancy M. Vold <[email protected]> Cc: sharon nelson <[email protected]>, Tyka Nelson <[email protected]>, Omarr Baker <[email protected]>, PresidentNelson <[email protected]>, Charles F. Spicer Jr. <[email protected]>, Jonas Herbsman <[email protected]>, Larry Mestel<[email protected]>

CONFIDENTIAL MEDIATION STATEMENT FOR THE MEDIATION IN THE PRN ESTATE TAX PAYMENT & TRANSITION DISPUTE:

Good Afternoon Justice Gilbert [Mediator],

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Thank you kindly,

L. Londell McMillan The NorthStar Group Chairman 240 W. 35th, Suite 405 New York, NY 10001

T: (646) 559-8314 F: (646) 559-8318 E: [email protected]

10-PR-16-46 Filed in District CourtState of Minnesota8/10/2021 4:58 PM