EFTA00143506.pdf

From: Sigrid McCawley < Subject: RE: Letters Rogatory Date: 30 November 2018 at 16:12:19 GMT To: Cc: ' ""Paul )" Stan Pottinger Hi - I should have been clearer. You can of course speak to your family but I am just cautioning you that you should not discuss the case or things your lawyers are telling you because that will break the privilege and they could be asked about conversations in their depositions. I am just trying to ensure that you protect yourself. Thanks Sigrid Sigrid McCawle Partner BOIES SCHILLER FLEXNER LLP Fort Lauderdale, FL. 33301 (am • www.bsfllp.com From: [mailto: ] Sent: Friday, November 30, 2018 11:09 AMTo: Sigrid McCawleyCc: Paul Cassell irj ); Stan PottingerSubject: Re: Letters Rogatory How can I not contact my entire family and I have been in recent contact with'? I have known him for 10 years.... On 30 Nov 2018, at 17:00, Sigrid McCawley wrote: EFTA00143506 Hello — these are the letters rogatory that Defendants are seeking that we discussed further on the phone. The defendants still have to seek approval from the court and we have already told them that we will be objecting to these depositions going forward but in full disclosure to you — it is highly likely that the Judge will allow anyone who has relevant information from the time period or information generally that could affect your claims to be deposed. As we discussed, both sides will have their own witnesses to present at trial. Please do not attempt to contact these witnesses (other than of course who ) because anything you say to them they can be asked about in deposition so you need to be very careful not to e-mail or speak to them in detail about the case or anything your lawyers have told you because that could result in a waiver of your privilege with your lawyers which would hurt your case. Take care and we will talk tomorrow. Sigrid Sigrid McCawleyPartner BOIES SCHILLER FLEXNER LLP Fort Lauderdale, FL, 33301 www.bsfllp.com The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or EFTA00143507 other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF'<Letter Rogatory - pdf5<Letter Rogato Mother.pdf><Letter Rogatory - df><Letter Rogatory - Leslie Ben•pdf><Letter Ro pdf><Letter Rogatory — and EFTA00143508