Counsel discusses timing and basis for filing a pleading in a 2014 litigation

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 22 you aS a practice to drop the footnote; was it in connection with this case or some other circumstance? A. It was -- as I recall, it was several years earlier. I don't know. Maybe a year or two earlier than this particular litigation, from what I remember. If I looked at some of my other pro bono cases around the country, we might be able to get a sharper time frame on that. I've done pro bono crime victims in a lot of cases. And the dean just thought it might be useful to have that kind of a footnote to avoid any misunderstanding. Q. Would you agree with me that in order to allow your name to be listed as counsel on this pleading, that you were required to have a sufficient basis for the allegations based on what you Knew as of December 30th, 2014? A. Sure. I think that's fair. Obviously, I imagine one of the issues we are going to discuss here today is what is a sufficient basis for filing a pleading like that. So, yeah, in general, of course, we had to have a sufficient basis for filing something like this and I firmly believe that we did. Q. And to put a point on my question, the way in which to measure the knowledge is as of December 30th, 2014, so the facts that came to your attention after ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021845