Re: Continued settlement discussions-Global

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Brad Edwards

Thanks. Will pass it on and will let you know what time will work

Sent from my iPad

On Jul 27, 2011, at 9:44 AM, "Brad Edwards" bedwards@pathtojustice.com wrote:

Anytime after 11.

Sent via BlackBeny by AT&T

-----Original Message-----

From: "CHRISTOPHER E. KNIGHT"

Date: Wed, 27 Jul 2011 08:57:07

To: Brad Edwards<b

Subject: Re: Continued settlement discussions-Global

Brad,

To assist Friday to run smoothly and more fruitful when today can you set aside 20 minutes to speak to my client directly by phone? Let me know and I will pass it on.

V V V

Chris

Sent from my iPhone

On Jul 26, 2011, at 9:08 PM, "Brad Edwards"

warts@patmojustice.com> wrote:

Chris,

We will prepare and send you the settlement documentation related to DK and CO, identical to that which was used in the last case. I will get it to you tomorrow so that your client can sign before our Friday meeting. >>

I am meeting with your client on Friday. There will be nobody else present, and nobody else (except Jack Scarola) will be alerted to the meeting. Jack will not be there, but he knows about it. You also have my assurance that there will be no service attempts and that these settlement discussions remain confidential.

Brad

-----Original Message-----

From: CHRISTOPHER E. KNIGHT [mailto:Cknight@fowler

Sent: Tuesday, July 26, 2011 8:13 PM

To: Brad Edwards

Subject: Re: Continued settlement discussions-Global

Brad,

Yes, this return email will confirm settlements in DK and CO subject to agreed settlement documentation

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being executed including confidentiality.

It is also my understanding that continued direct settlement discussions between just you and my client on global issues will occur Friday morning with the same agreements regarding all discussions being protected as well as an agreement that you will not attempt to alert others of the meeting and that no attempts on service of any kind will be made.

Please confirm by return email. Best of luck to both of you in getting all actions against each other resolved.

Best regards,

Chris

Sent from my iPad

On Jul 26, 2011, at 2:52 PM, "Brad Edwards" bedwards@pathtojustice.com wrote:

Chris,

We settled the two victim cases for $225k total, to be split up 90k to CO and 135 to DK. As we did last time, please send over the settlement papers asap as well as assure me that the money will be wired to our trust account fairly quickly (I believe we have received within 7 days of settlement papers being signed in the past). If you are out of the office and thus would prefer my office to prepare the papers and send them to you, then we will do that consistent with those prepared in previous cases.

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-----Original Message-----

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From: CHRISTOPHER E. KNIGHT [mailto:CKnight@fowler-white.com]

Sent: Tuesday, July 26, 2011 8:06 AM

» To: Brad Edwards

Subject: Re: Continued settlement discussions-Global

Brad,

My client is planning to call you to follow up directly. Any comments that happen to be made by the two of you of course will be considered protected settlement discussions. Hopefully this will speed things up in light if your time restraints.

Best regards,

Chris

Sent from my iPhone

On Jul 25, 2011, at 8:08 PM, "Brad Edwards" bedwards@pathtojustice.com wrote:

Chris,

I do not think the phone will be nearly as productive as his original idea to do it in person. My primary issue right now is time, so I would propose setting this Friday (July 29th) aside for us to meet in Palm Beach. I recommend Jack Scarola's office. Just me and your client in the room, but in case any attorney client type issues arise I would like for Jack to be nearby without him needing to block off his schedule.

Talk to your client and get back to me. If we are doing it Friday, then you and I can work through any conditions/parameters, which should not be difficult. >>>> Brad >>>> >>>> -----Original Message----- >>>> From: CHRISTOPHER E. KNIGHT [mailto:ЄKnight@fowler-white.com] >>>> Sent: Monday, July 25, 2011 7:50 PM >>>> To: Brad Edwards >>>> Subject: Continued settlement discussions-Global >>>> >>>> Brad, >>>>> >>>> I look forward to following up with you. I have spoken with my client who is willing to speak with you on the phone under the same parameters we discussed this afternoon regarding not using any statements made during the conference in further proceedings and that it is just the two of you on the line. >>>> >>>> Best regards, >>>> Chris >>>>> >>>> >>>> >>>> Sent from my iPad >>>> **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter

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TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.* ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you.

TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.* ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you.