Re: ATTORNEY-CLIENT and COMMON INTEREST AGREEMENT

slomans letter says they will review with us the list if we have questions it also said short of 40, we never got the opportunity is this an opening for alan to go in and say he woudl like see why virginia is on the list. . the footnote is noting that they had on a flight to the vi, in 2001 but the statute of limits had expired

Yes, a possible response for Alan is that her virulent allegations have never been examined. She speaks to the media – 2011 UK in particular – she then gives an “ex parte” taped interview to Scarola who is representing Edwards – she then files multiple affidavits in the CVRA all of which were stricken, none of which were able to be disputed at a hearing – and now an affidavit she is afraid of Alan – and when its time for someone to question her they move to quash

I think Kendall might have the relationships to ask that question but Alan is out of the CVRA, we remain in it, if she is ever relied upon again by Edwards in their upcoming Summary Judgment motion, we should ask the Govt to consider that not only did they properly object to her joining the case, she should be stricken as a witness given that she disqualified herself by refusing to cooperate and then got a windfall by being listed at a time we assumed there was some relationship between victims and witnesses under the Sloman formulation — and in that conversation ask how she (in contrast eg to made it onto the witness list

should you reach out to [REDACTED] and get her thoughts. would she mind if alan asked how [REDACTED] was put on the list. ?

Yes
Thru kendall

Sent from my iPhone

ok you suggest to alan

Will do.

The timing is not right for me to call - she (or Dexter) have no due dates, no issues, they are just waiting for either J Marra to resolve all the open discovery issues (their 14,000 withheld pgs with 6E and privilege issues) or for Cassell to file (after all these years) his motion for summary judgment.
When they have to do an answer, and there is a reason for a call to discuss issues, and particularly if they raise in any respect in any motion, then it would be a shorter leap to ask the question than now when she would think why do you want the answer and retreat to 6E objection.
Kendall, however, now that the CVRA issue is over, can ask will be far less on guard if its coming from his helping Alan than my helping you)

A future decision is the timing of enforcing the Settlement Agreement. Its not ripe until remedy, but my instinct is to file it before any ruling on liability - such a ruling (it may be years off since he has previewed that he intends to have a hearing) would be an opportunity for J Marra to narrow the possible remedies at issue in any followup phase so we would want him to know this issue exists if the NPA is still (would be 9-10 yrs later) still in play. Want me to discuss with Roy who has been before and knows J Marra for his views ? Kathy?

not now. i want to focus on alan getting vr depo . and info