Re: 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
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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
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
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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.
Brad Edwards
Civil Justice Attorney
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale Florida 33301
Telephone:
Facsimile: 954-524-2822
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www.pathtojustice.com
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Brad,
Yes, this return email will confirm settlements in DK and CO subject to agreed settlement documentation 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
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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
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.
Chris
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