Ellen A. Pansky (SBN 77688)
Art Barsegyan (SBN 279064)
PANSKY MARKLE ATTORNEYS AT LAW
1010 Sycamore Ave., Suite 308
South Pasadena, CA. 91030
Telephone: (213) 626-7300
Facsimile: (213) 626-7330
Attomeys for Respondent
Michael J. Avenatti, Esq
FILED
weir aoe HE
STATE BAR COURT
CLERK'S OFFICE,
LOS ANGELES
BEFORE THE STATE BAR COURT
OF THE STATE OF CALIFORNIA
HEARING DEPARTMENT — LOS ANGELES
In the Matter of
MICHAEL JOHN AVENATTI,
Member No. 206929,
A Member of the State Bar.
Case No. SBC-19-TE-30259-YDR
RESPONDENTS STATEMENT RE
EVIDENCE TO BE OFFERED AT THE
HEARING
[Rules 5.230(B) of the Rules of Procedure]
Pursuant to Rules of Procedure, rule 5.230(B), Respondent offers the following statement
regarding the written evidence he seeks to offer at the hearing in this matter:
1. Claim for Arbitration, dated January 29, 2019, filed by Greg Barela, attached hereto as
Exhibit A;
2. The email correspondence between Respondent and his legal counsel with Brian Weiss and
his legal counsel John Reitman, which were attached to the declarations in support of
Respondent's Reply re Motion for Continuance filed on July 17, 2019;
RESPONDENT'S STATEMENT RE EVIDENCE TO BE OFFERED AT HEARINGCm ae
‘The Joint Report dated July 1, 2019, and Minute Order dated July 8, 2019, from the pending
criminal proceeding, which were attached to the declaration in support of Respondent's
Motion for Continuance filed July 11, 2019;
|. E-mail correspondence with Greg Barela (provided Respondent is granted access to said
documents);
Cost and Accounting documents relating to Barela matters (provided Respondent is granted
access to said documents);
. Settlement Drafis and Agreement (provided Respondent is granted access to said
documents);
. Pleadings and filings from Barela matters (provided Respondent is granted access to said
documents):
. Text messages with Greg Barela (provided Respondent is granted access to said documents):
and
E-mail and text correspondence with other attorneys and parties in connection with Barela
‘matters (provided Respondent is granted access to said documents).
Respondent reserves the right to offer any addition written evidence to impeach any witness,
including but not limited to Mr, Barela.
Respectfully submitted,
Dated: July 17,2019 PANSKY MARKLE
ATTORNEYS AT LAW
By:
An Barkdg¥an
Attomeys for Respondent
Michael J. Avenaiti
1
RESPONDENT'S STATEMENT RE EVIDENCE TO BE OFFERED AT HEARINGExhibit A