EFTA01029079.pdf

From: Noam Chomsky To: "jeffrey E." <[email protected]> Cc: Valeria Chomsky Subject: Fwd: FW: settlement agreement Date: Wed, 06 Feb 2019 21:02:12 +0000 Attachments: Chomskyn Settlement_Agreementired-line_of initial_draft_by_Hirsch).DOCX; Chomsky_-_Mutual_Release.DOCX Inline-Images: image001.png; image002.png; image003.png What do you think about these? Noam Forwarded message From: Vincent Pisegna Date: Wed, Feb 6, 2019 at 1:24 PM Subject: FW: settlement a reement To: Noam Chomsky , Valeria Chomsky < Cc: Jason B. Curtin Noam and Valeria - here is the latest documents. Perhaps you should review them before we chat. I think you've looked at the Settlement Agreement but I've also attached the Releases document. Let me know when you've reviewed this material and we'll set up a call. From: Vincent Pisegna Sent: Wednesday, February 06 2019 3:20 PM To: 'Milan Hirsch' ;'George A. Berman' < Cc: Jason B. Curtin Subject: RE: settlement aurcement Attached is a redline ofJillian's proposed Settlement Agreement and a draft Releases document for your review. By email to you dated January 15, 2019, I forwarded to you the name of Bob Holdway of Fiduciary Trust to act as successor trustee but have not heard back from you. Please confirm that he is acceptable. Per the "game plan" below that we previously agreed-to, there are still a number of documents which you need to produce. Jillian, you need to draft a motion to approve the settlement and George, you have a host of mostly transactional documents to draft. Can we get those loose ends cleaned up so we can send notice out to the interested parties before the March 13 hearing with the hope that we can obtain court approval that day and complete the settlement. The parties entered into the settlement agreement almost a month ago. EFTA01029079 Thanks. Vincent J. Pisegna Krokidas & Bluestein LLP 600 Atlantic Avenue Boston, MA 02210 Tel: Fax www.kb-law.com From: Vincent Pisegna Sent: Monday, January 14, 2019 5:24 PM To: Jillian Hirsch ; George A. Berman Cc: Jason B. Curtin Subject: RE: settlement agreement Per our call today, here is the game plan for putting together the final documentation: 1. Tax counsel re Note - VP is working on this. Hope to have something soon. Jillian or George, can you get me the last two tax returns for the Trust. Thanks. 2. Institutional trustee - I hope to send you a name shortly. 3. Settlement agreement - JH will prepare a draft. 4. Releases - VP will prepare a draft. 5. Motion for approval of settlement - JH will prepare a draft. 6. Notice to daughters - JH thinks Harry has spoken with them and that they can await the formal documentation when they assent to the settlement. 7. Waiver of principle distributions - GB. 8. Waiver of POA by Noam - GB. EFTA01029080 9. Resignation of trustees - GB. 10. Assent of children and grandchildren to settlement - GB. 11. Checks for $750,000, $45,000 for NC legal reimbursement, $45,000 for HC legal reimbursement, $5,000 for NC mediators fee reimbursement 12. Documentation of distribution of Note to NC - VP. 13. Stipulations of dismissal - JH. Please let me know if any changes are necessary. Thank you for your cooperation. Vincent J. Pisegna Krokidas & Bluestein LLP 600 Atlantic Avenue Boston, MA 02210 Tel: Fax www.kb-law.com From: Jillian Hirsch <1 Sent: Friday, January Il, 2019 1:47 PM To: Vincent Pisegna ; George A. Berman Cc: Jason B. Curtin Subject: RE: settlement agreement 4pm is fine. Jillian B. Hirsch I Attorney at Law 2logo2 275 Grove Street, Suite 2-400 I Newton, MA 02466 EFTA01029081 t www.hirschlawllc.com This message contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended solely for the use of the addressee(s) named above. Any disclosure, distribution, copying or use of the information by others is strictly prohibited. If you have received this message in error, please notify the sender by immediate reply and delete the original message. Thank you. From: Vincent Pisegna < Sent: Friday, January 11, 2019 1:45 PM To: Jillian Hirsch ; George A. Berman Cc: Jason B. Curtin Subject: RE: settlement agreement As it turns out 4:00 is better for me on Monday and 11:00 is not very good. From: Jillian Hirsch Sent: Friday, January 11, 2019 12:31 PM To: George A. Berman ; Vincent Pisegna Cc: Jason B. Curtin Subject: RE: settlement agreement Il works for me. Jillian B. Hirsch I Attorney at Law 2Jogo2 275 Grove Street, Suite 2-400 I Newton, MA 02466 t This message contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended solely for the use of the addressee(s) named above. Any disclosure, distribution, copying or use of the information by others is strictly prohibited. If you have received this message in error, please notify the sender by immediate reply and delete the original message. Thank you. EFTA01029082 From: George A. Berman Sent: Friday, Janua 11, 2019 12:25 PM To: Jillian Hirsch ; Vincent Pisegna Cc: Jason B. Curtin Subject: RE: settlement agreement I am pretty flexible Monday, but for the sake of suggesting a time, how about 11 or 4? From: Jillian Hirsch [mailto: Sent: Friday, January 11, 2019 12:09 PM To: Vincent Pisegna Cc: George A. Berman; Jason B. Curtin Subject: RE: settlement agreement That works for me. What time is best? Jillian B. Hirsch I Attorney at Law litogo2 275 Grove Street, Suite 2-400 I Newton, MA 02466 www.hirschlawllc.com This message contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended solely for the use of the addressee(s) named above. Any disclosure, distribution, copying or use of the information by others is strictly prohibited. If you have received this message in error, please notify the sender by immediate reply and delete the original message. Thank you. From: Vincent Pisegna < Sent: Friday, January 11, 2019 10:52 AM To: Jillian Hirsch Cc: George A. Berman Jason B. Curtin Subject: settlement agreement Can we do a call on Monday to discuss the work to finalize the settlement, e.g., drafting a settlement agreement? Vincent J. Pisegna EFTA01029083 Krokidas & Bluestein LLP 600 Atlantic Avenue Boston, MA 02210 Tel: Fax www.kb-law.com This transmission is intended only for the designated recipient(s). It contains confidential information that may be subject to the attorney-client privilege or other confidentiality protections under applicable law. If you are not a designated recipient, you must not read, use, copy or distribute this message. If you received this transmission in error, please notify the sender by telephone (617-951- 2100) or by reply e-mail and delete this message. IRS Circular 230 requires that we inform you that if this communication (including any attachments) contains tax advice, it is not intended or written to be used, and cannot be used, for purposes of avoiding penalties under the Internal Revenue Code, or promoting marketing or recommending to another party any transaction or matter addressed herein. EFTA01029084