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

From: "Jeffrey E." <[email protected]> To: "Martin B. O'Connor II" Subject: Re: Attorney-Client Privileged Communication Date: Wed, 10 Dec 2014 20:07:27 +0000 Yes On Wed, Dec 10, 2014 at 4:07 PM, Martin B. O'Connor II < > wrote: By finance you mean pay 175 at a later period45/60 days. Yes? Martin B. O'Connor, II, Esq. O'Connor, Morss & O'Connor, P.C. Post Office Box 979 Elizabeth, New Jersey 07207-0979 On Dec 10, 2014, at 12:01 PM, "jeffrey E." <[email protected]> wrote: get the first 426 and have gary agree now to finance 175 or pay 150 now. not sure why this can't be done in a phone call. On Wed, Dec 10, 2014 at 12:35 PM, Peggy Siegal < > wrote: What's going on. I don't understand. It feels like Gary does not have the money to pay me...which is exactly what was saying for three years. He is a thief. From: Martin B. O'Connor II [mono: Sent: Wednesda December 10 2014 10:10 AM To: >; Peggy Siegal Subject: RE: Attorney-Client Privileged Communication Jim and Peggy, I am back in the office this afternoon and will call you, Jim and thereafter reach out to Jamie. M Martin B. O'Connor, II, Esq. O'Connor, Moms & O'Connor, P.C. Mailing Address: P.O. Box 979 Elizabeth, New Jersey 07207-0979 EFTA01002350 For Federal Express and Hand Deliveries: Liberty Hall Center 1085 Morris Avenue, 5th Floor Union, New Jersey 07083 This e-mail message from the law firm of O'Connor, Morss & O'Connor is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Please be advised that based on current IRS rules and standards, the advice contained herein is not intended to be used, nor can it be used, for the avoidance of any tax penalty that the IRS should assess related to this matter. That said, please do not hesitate to call me if you have any further questions regarding this matter. From: Sent: Tuesday, December 09 2014 10:04 AM To: Martin B. O'Connor II; Subject: Attorney-Client Privileged Communication Martin and Peggy As I mentioned to Martin when we spoke this morning, Ms. Dyce advised me yesterday evening that Gary has been working diligently to obtain financing to pay the $150,000 part of the payment due Peggy under the proposed agreement. As you can see from the e-mail below, Gary hopes to have an answer regarding financing today. She has not wanted Gary to sign the agreement when Gary is still working on the financing because Gary would be exposed to liability for attorney fees if he defaults on the $150 payment. (At least that explains why she was unresponsive). She also explained that the reserve fund of $40,000 has, or is exhausted, by professional fees for the estate and trust (predominantly her firms services for an extended period of time). Therefore, she advises me that Gary is prepared to make immediate payment of the $426 but needs more time than 15 days for the $150. (What she would really like is for Gary to pay Peggy over time). As Martin mentioned getting the money out of Gary's hands makes sense. Perhaps the most cost efficient route, subject to Peggy's approval, is to revise the agreement to provide that Gary will make immediate payment of the $426 by wire and give him 45 or 60 days to obtain financing for the $150 and tell Ms. Dyce that this has to be wrapped up this week otherwise Peggy will seek her remedies in court. I will let you know if I hear from Ms. Dyce regarding the financing today. I doubt it. EFTA01002351 Jim James R. George Shareholder Greenberg Traurig, P.A. 1401 East Las Olas Boulevard Suite 2000 I Fort Lauderdale, FL 33301 <image001.jpg> From: Dyce, Jamie R. [mailto: Sent: Monday, December 08, 2014 5:33 PM To: Geor e James R. Shld-FTL-LT) Cc: Subject: RE: Call Today Thanks for speaking with me today. I spoke with Gary, he has a meeting with Capital One tomorrow and a call expected from Bank of America. I will let you know as soon as I have an update. Jamie R. Dyce Associate Duane Morris LLP 1540 Broadway New York. NY 10036-4086 0..110 A71 gime In compliance with U.S. Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used, and cannot be used. for the purpose of (i) avoiding tax penalties or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. From: [mailto: Sent: Monday, December 08, 2014 3:53 PM To: Dyce, Jamie R. Subject: RE: Call Today EFTA01002352 YEs From: Dyce, Jamie R. [mailto: Sent: Monday, December 08, 2014 3:53 PM To: Geor e James R. Shld-FTL-LT) Cc: Subject: RE: Call Today I need a few, can we do 4:30? Thanks. Jamie R. Dyce Associate Duane Morris LLP 1540 Broadway AM/ innolc •CLOC In compliance with U.S. Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used. and cannot be used. for the purpose of (i) avoiding tax penalties or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. From: [mailto Sent: Monday, December 08, 2014 2:24 PM To: D ce Jamie R. Cc: Subject: FW: Call Today Jamie Martin asked that I speak with you this afternoon as you suggested. Does 4:00 p.m. work with your schedule? Jim EFTA01002353 From: George, James R. (Shld-FTL-LT) Sent: Monday, December 08, 2014 8:23 AM To: 'Dyce, Jamie R.'; Martin B. O'Connor II Cc: Pat Zwarycz Subject: RE: Call Today Jamie What time should I call you? Jim From: Dyce, Jamie R. [mailto: Sent: Friday, December 05, 2014 3:45 PM To: Martin B. O'Connor II Cc: George, James R. (Shld-FTL-LT); Pat Zwarycz Subject: RE: Call Today IN sorry, I cannot do today. Monday afternoon? Jamie R. Dyce Associate Duane Morris LLP 1540 Broadway 086 In compliance with U.S. Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used, and cannot be used. for the purpose of (i) avoiding tax penalties or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. From: Martin B. O'Connor II [mailto: Sent: Friday, December 05, 2014 2:47 PM To: Dyce, Jamie R. Cc: Jim George; Pat Zwarycz Subject: Call Today EFTA01002354 Jamie, Could we have a call today at 5:30 I..? I have included our dial in details Access Code 4236591. Please reply all. Best, Martin B. O'Connor, II, Esq. O'Connor, Morss & O'Connor, P.C. Mailing Address: P.O. Box 979 Elizabeth, New Jersey 07207-0979 For Federal Express and Hand Deliveries: Liberty Hall Center 1085 Morris Avenue, 5th Floor Union, New Jersey 07083 This e-mail message from the law firm of O'Connor, Morss & O'Connor is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Please be advised that based on current IRS rules and standards, the advice contained herein is not intended to be used, nor can it be used, for the avoidance of any tax penalty that the IRS should assess related to this matter. That said, please do not hesitate to call me if you have any further questions regarding this matter. For more information about Duane Morris. please visit Confidentiality Notice: This electronic mail transmission is privileged and confidential and is intended only for the review of the party to whom it is addressed. If you have received this transmission in error, please immediately return it to the sender. Unintended transmission shall not constitute waiver of the attorney-client or any other privilege. If you are not an intended recipient of confidential and privileged information in this email, please delete it, notify us immediately at and do not use or disseminate such information. EFTA01002355 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 EFTA01002356