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Homechevron_right Emailchevron_right Fwd: FTC and COUQ
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Fwd: FTC and COUQ

1 message attach_file 3 attachments picture_as_pdf Source PDF
?
DKIESQ@aol.com Apr 14, 2008 4:08 PM
To
<jeeproject@yahoo.com>
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
 
------------------------------
IRS Circular 230 Legend: Any advice contained herein was not intended or written to be used, and cannot be used, for the purpose of avoiding U.S. federal, state, or local tax penalties. Unless otherwise specifically indicated above, you should assume that any statement in this email relating to any U.S. federal, state, or local tax matter was written in connection with the promotion or marketing by other parties of the transaction(s) or matter(s) addressed in this email. Each taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.
================================================================= 
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
=================================================================




It's Tax Time! Get tips, forms and advice on AOL Money & Finance.

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

Confidentiality Notice: The information contained in this e-mail and any attachments may be legally privileged and confidential. If you have received this e-mail in error, please notify the sender and permanently delete the e-mail and any attachments immediately. You should not retain, copy or use this e-mail or any attachment for any purpose, nor disclose all or any part of the contents to any person. Thank you.

 

3 attachments
PDF
Claims to be Asserted Against Bear Stearns..pdf 226 KB
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PDF
Retainer.Apr11.Redline to Apr4.pdf 624 KB
download open_in_new
PDF
Retainer.Apr11.pdf 598 KB
download open_in_new

1419 files from the DOJ Epstein case media release. All files are public records from justice.gov.

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