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efta-efta00340528DOJ Data Set 9Other

From: "Jeffrey E." <[email protected]>

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Unknown
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DOJ Data Set 9
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efta-efta00340528
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: "Jeffrey E." <[email protected]> To: Lesley Groff Subject: Re: ATTORNEY-CLIENT PRIVILEGE Date: Fri, 11 Sep 2015 13:12:35 +0000 Yes On Fri, Sep 11, 2015 at 3:10 PM, Lesley Groff < > wrote: Do you want Darren on this call at 2pm today also? Sent from my iPhone On Sep 11, 2015, at 8:59 AM, jeffrey E. <[email protected]> wrote: Forwarded message From: Martin G. Weinberg Date: Fri, Sep 11, 2015 at 2:19 PM Subject: Re: ATTORNEY-CLIENT PRIVILEGE To: "jeffrey E." <jeevacation@ga, 2 PM today. Please send a # to Alan and me. His lawyers working with Sigrid to assign a date to the deposition He thinks Pottinger is a lawyer for VR. I said generally he said he wasn't but didn't want to give detail (eg RW) He has multiple policies, malpractice, bus liability, umbrella, plenty of coverage, 4M per incident on malpractice From: jeffrey E. Sent: Friday, September 11, 2015 6:51 AM To: Martin Weinberg Subject: Re: ATTORNEY-CLIENT PRIVILEGE today anytime or monday also ok On Fri, Sep 11, 2015 at 1:55 AM, Martin Weinberg < > wrote: That requires a you-me-alan call first since alan is at zero from his insurers equating it to an admission We need to get him to understand a pathway out of his risky case before speaking with insurance attys Sent from my iPhone On Sep 10, 2015, at 7:43 PM, "jeffrey E." <[email protected]> wrote: i need to know aprox how much theyare willing to pay to settle.. On Fri, Sep 11, 2015 at 1:13 AM, Martin Weinberg <MI EN> wrote: Policies exceed 2 Will have more details Sent from my iPhone On Sep 10, 2015, at 5:44 PM, Martin Weinberg < II> wrote: EFTA00340528 Will stay on him to get detail and limits So you know, when i opened this discussion he said he was against either his insurer ( or himself) funding a deal Sent from my iPhone On Sep 10, 2015, at 4:16 PM, "jeffrey E." <[email protected]> wrote: I will attempt a settlement on tues or wed , I need to know how much his insureance co is willing to chip in. Im hoping for 2 million On Thu, Sep 10, 2015 at 10:13 PM, Martin G. Weinberg <-> wrote: His coverage is from malpractice and umbrella policies. Expect more info re amounts per "incident" today. Martin G Weinberg PC 20 Park Plaza Suite 1000 please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for EFTA00340529 the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00340530

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48

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