Ali,
Thank you for your counterproposal. We remain hopeful that the case can be settled and are committed to working with your office toward this goal.
We need a bit more clarity on what is being proposed. I'd like an ongoing dialogue as we move closer to settlement. Here are some current questions:
- Is your client now limiting her breach of fiduciary duty claims to the transactions she has identified?
- Should we accept your counterproposal, would the case be fully resolved, or will the resolution depend on my client's responses regarding the transactions in question?
- Under your counterproposal, what items are to be confirmed as your client's separate property, and my client's separate property, and what would the split of community property and assignment of debts be? Does that split conform to our proposed MSA's Sections 2.2.1 through 2.2.4?
- If there is a different split being proposed, please advise.
- I was not my client's first attorney. Is there a prior stipulation or Court Order concerning the payment of attorney's fees?
Email me your responses and let's move this forward.
R. Dwyer, Esq.
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Richard e. a. Dwyer esq.
California Attorney, Lic. # 143883
NO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept e-mail notice for ex parte Applications via voicemail or by email. You must comply with California Law and give notice to a person in my office during regular business hours.
CONFIDENTIALITY NOTICE: This e-mail transmission (and/or the attachments accompanying it) may contain confidential information belonging to the sender which is protected by the attorney-client privilege. The information is intended only for the use of the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this information is strictly prohibited. Any unauthorized interception of this transmission is illegal. If you have received this transmission in error, please promptly notify the sender by reply e-mail, and then destroy all copies of the transmission.
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