I sent the attached memo to you on Friday, but just in case, I am sending
it again. I left a message for Steve and spoke to Jason Levin, explaining
that while I do not disagree with the basic theories of liability outlined in
the memo, what we were supposed to receive was a more detailed factual
time-line, so that we can review the facts as a group and determine which ones
to present and how to present them during the telephone call with Bear's
attorney. Telling Bear's attorney that we will bring a claim for
fraudulent inducement and common law fraud for $20 MM, without going into
certain facts regarding, for
example, Warren's misrepresentations reckless behavior, is not
going to cause them to deal with us separately from everyone else. The
presentation has to be specific and demonstrate unique facts to our case,
as well as particularly harmful facts against Bear. In any
event, I left a message for Steve to call me after his deposition today and will
discuss that with steve in detail. If you have anything you want to add,
please let me know.
Darren K.
Indyke
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New
York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
------------------------------
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| From: | Jason Levin <jlevin@samlegal.com> | |
| Subject: | FTC and COUQ | |
| Date: | Fri, 11 Apr 2008 20:24:03 GMT | |
| To: | dkiesq@aol.com | |
| Cc: | Steven Storch <sstorch@samlegal.com> | |
Darren
Attached please find three documents. The first document
is the revised engagement letter reflecting our discussion on Tuesday. The
second document is a redline version of the engagement letter comparing the
current version to the prior version you reviewed. Finally, attached is a
memorandum reflecting our current thinking.
Regards,
Jason
Jason Levin
Storch Amini & Munves PC
2 Grand Central Tower, 25th
Floor
New York, New York 10017
Tel: 212.490.4100
Direct: 212.497.8218
Fax: 212.490.4208
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Thank you.
Claims to be Asserted Against Bear Stearns..pdf 226 KB
Retainer.Apr11.Redline to Apr4.pdf 624 KB
Retainer.Apr11.pdf 598 KB