EXHIBIT A
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Fleming, Joel
From: Jeanette T. Barzelay <JBarzelay@kasowitz.com> Sent: Friday, March 15, 2013 2:07 PM To: Shapiro, Jonathan; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan; Charles N. Freiberg; Jacob N. Foster Subject: RE: Deposition notices
Jonathan, As you know, we gave you advance notice, on Tuesday, March 5 – six days before we filed our motion on Monday, March 11 – that we would be setting the hearing date for April 8. Nevertheless, we did not hear about your purported conflict until two days after we filed our motion, on March 13. We will be opposing your ex parte motion on the basis explained in our previous emails, including the fact that it is an attempt to delay our motion in order to cure the untimeliness of your motion. Thanks, Jeanette Jeanette T. Barzelay Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655-4346 Fax (650) 745-2866 JBarzelay@kasowitz.com
From: Shapiro, Jonathan [mailto:Jonathan.Shapiro@wilmerhale.com] Sent: Friday, March 15, 2013 9:20 AM To: Jeanette T. Barzelay; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan; Charles N. Freiberg; Jacob N. Foster; Shapiro, Jonathan Subject: RE: Deposition notices Jeanette, I just tried you at your office; left vm. We are planning to file later today an ex parte motion to move the hearing date from 4/8 until 4/22 (the date that you previously said would work on your end), or alternatively to 4/15. As I said on the vm, I’d love to persuade you to reconsider. In any event, all this scheduling/housekeeping really could be avoided if you would simply ask us if a date works before unilaterally assuming as much; I realize that there isn’t a rule that requires folks to consult on dates, but it really would make life easier. Thanks, Jonathan Jonathan A. Shapiro | WilmerHale 950 Page Mill Road Palo Alto, CA 94304 USA +1 650 858 6101 (t) +1 650 858 6100 (f)
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jonathan.shapiro@wilmerhale.com Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
From: Shapiro, Jonathan Sent: Thursday, March 14, 2013 2:59 PM To: 'Jeanette T. Barzelay'; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan; Charles N. Freiberg; Jacob N. Foster; Shapiro, Jonathan Subject: RE: Deposition notices Jeanette, March 25 was a typo and I meant March 11. We plainly disagree about whether LSW’s filing will be timely, and that’s for the Court to decide. What I was trying to say is that LSW is not going to argue that the March 11 deadline has moved as a result of rescheduling the hearing. That is, whatever argument you want to make about timeless, doesn’t change one bit (and we are not trying to obtain any advantage in that regard). I’m not sure why you are connecting my child care challenge on 4/8 to the court filing deadlines. We’ve told you what we are filing, and when (on Monday) and I have never asked, suggested, etc. that we would like more time for any of that. My scheduling issues on 4/8 have nothing to do with the case. All I asked for was a week delay to the 15th or to the 22nd (a date you said worked). Jonathan Jonathan A. Shapiro | WilmerHale 950 Page Mill Road Palo Alto, CA 94304 USA +1 650 858 6101 (t) +1 650 858 6100 (f) jonathan.shapiro@wilmerhale.com Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
From: Jeanette T. Barzelay [mailto:JBarzelay@kasowitz.com] Sent: Thursday, March 14, 2013 1:35 PM To: Shapiro, Jonathan; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan; Charles N. Freiberg; Jacob N. Foster Subject: RE: Deposition notices Jonathan,
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The Court explicitly ordered that “any motions concerning the class notice and any disputes among the parties concerning the content of the class notice” must be filed within ten days after the Ninth Circuit’s denial of LSW’s Rule 23(f) petition – this past Monday, March 11. LSW did not file any such motion. You then made a request to move the April 8 hearing date on Plaintiffs’ motion based solely on your personal schedule without ever mentioning that LSW would avail itself of the additional time to file its own motion that would otherwise be untimely. Further, since you were aware of the April 8 hearing date as early as last Tuesday, March 5 (see Freiberg email), if you had a scheduling conflict, you should have raised it last week. Your belated request and your email below make plain that your intention in proposing this continuance based on your personal scheduling conflicts was, in the main, to gain additional time to prepare LSW’s untimely motion. This was pure gamesmanship. LSW could have (and should have) ensured that its motion would be timely and heard at the same time as Plaintiffs’ motion by filing its motion this past Monday. LSW’s motion for appointment of a special master is now untimely pursuant to the Fourth Amended Pretrial Scheduling Order. The dispute concerning the timing for appointment of a special master necessarily “concern[s] the class notice” and is raised by the class notices LSW proposed and the dispute between the parties concerning the notice. See, e.g., LSW’s Proposed Notice Distributing Questionnaire at 8 (stating, “The Court is currently deciding membership in the sub‐ Class. In order to do this, the Court has appointed a so‐called “Special Master” to assist the Court in its review of materials from LSW’s policy files in order to determine what materials, if any, potential Class Members received. In addition, the Court has directed that the attached questionnaire be distributed to potential Class Members to assist the Special Master in determining whether you and other policyholders are members of the sub‐Class); March 8 letter (“LSW believes that the special master process must begin immediately – in concert with the ‘response‐required class notice’”). This is why we raised the issue in our opening motion papers. If LSW wanted to separately move for appointment of a special master, the time to do so was this past Monday, March 11. We also do not understand your reference to some “March 25” deadline for LSW’s now untimely and improper motion. The March 25 deadline to which I referred in my email would be the new deadline for LSW’s opposition to Plaintiffs’ motion if the hearing date on that motion was moved to April 22. Our agreement to stipulate to moving the hearing date was conditioned, however, on LSW’s agreement not to take advantage of the additional two weeks and the new April 22 hearing date in order to file a separate motion that would otherwise be untimely. Nor do we understand what “papers” you believe “we agreed would be filed Monday” or your reference to “Monday’s deadline.” We did not agree that LSW could file a separate motion concerning class notice issues after the deadline set by the Fourth Amended Pretrial Scheduling Order had passed, or at the time it filed its opposition. Further, although you informed us on March 8 of your intention to bring a separate motion, nothing in your letter suggested that you would do so at the time LSW’s opposition to Plaintiffs’ motion would be due (your letter stated, “we will bring a motion at the same time that the parties are addressing notice content,” not that you would bring it “in connection with opposing” our motion), and we certainly did not “agree” that LSW could file such a motion at the same time as its opposition papers and still be timely. Moreover, your email suggests that it was always LSW’s intention to “notice [its motion] for the same hearing date,” but if that is the case, your motion would have had to be filed this past Monday in order to be timely for the April 8 hearing date. We informed you on March 5 that we would notice our motion to be heard on April 8. See Freiberg email. Moreover, as your letter confirms, LSW obviously has been aware of its position concerning the appointment of a special master “in concert with the ‘response‐required class notice’” for months. See March 8 letter (stating that you “have described LSW’s position to [Plaintiffs] previously, so [you] will not reiterate it at length”); February 22 proposed class notices (expressly referencing the appointment of a special master in connection with class notice). Thus, there is no reason why LSW could not have filed its motion on Monday, March 11 and secured the same hearing date for that motion as for Plaintiffs’ motion concerning class notice issues. Accordingly, Plaintiffs do not agree to move the April 8 hearing date on their motion concerning class notice issues. Regards, Jeanette
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Jeanette T. Barzelay Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655-4346 Fax (650) 745-2866 JBarzelay@kasowitz.com
From: Shapiro, Jonathan [mailto:Jonathan.Shapiro@wilmerhale.com] Sent: Thursday, March 14, 2013 8:09 AM To: Jeanette T. Barzelay; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan; Charles N. Freiberg; Jacob N. Foster; Shapiro, Jonathan Subject: Re: Deposition notices Jeanette – Thanks for your response. The schedule that you proposed is fine with us. We also agree that moving this hearing date will not move the March 25 deadline. However, just to be clear, as we informed Plaintiffs previously, in connection with opposing Plaintiffs’ motion for class notice, LSW will be moving for appointment of a special master, and we will notice that for the same hearing date. These are the papers we agreed would be filed on Monday, and they still will be (we're not trying to bump Monday's deadline). LSW does not believe such a motion is subject to the March 25 deadline. I suppose if you disagree, your clients can certainly oppose on timeliness grounds. But, for present purposes, suffice it to say that whatever deadline passes on March 25 is not altered by the stipulation we’re now discussing, ok? Thanks, Jonathan Jonathan A. Shapiro | WilmerHale 950 Page Mill Road Palo Alto, CA 94304 USA +1 650 858 6101 (t) +1 650 858 6100 (f) jonathan.shapiro@wilmerhale.com Please consider the environment before printing this email.
From: Jeanette T. Barzelay [mailto:JBarzelay@kasowitz.com] Sent: Wednesday, March 13, 2013 07:58 PM Eastern Standard Time To: Shapiro, Jonathan; Perla, Timothy; Lux, James; Robinson, Andrea Cc: Brian P. Brosnahan <BBrosnahan@kasowitz.com>; Charles N. Freiberg <CFreiberg@kasowitz.com>; Jacob N. Foster <JFoster@kasowitz.com> Subject: RE: Deposition notices
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Jonathan, We are amenable to moving the hearing date to April 22, provided that LSW agrees to split the difference with respect to the two additional weeks so that both parties will have an additional week to prepare their respective papers. That is, contrary to the presumptive deadlines set forth in Local Rule 7‐11, LSW’s opposition papers would be due on Monday, March 25 (not Monday, April 1), and Plaintiffs’ reply papers would be due on the presumptive deadline, April 8, which would give both LSW and Plaintiffs two weeks (as opposed to the usual one week) to prepare responsive papers. We want to be clear, however, that we do not want LSW to use this continuance and our agreement to stipulate thereto to secure additional time to make its own motion concerning the class notice (since such a motion, if filed now, would be untimely for an April 8 hearing date), which, in your March 8 letter, you suggested LSW might do. Even if properly and timely noticed under the Local Rules, such a motion would be untimely pursuant to the Fourth Amended Pretrial Scheduling Order. Assuming you agree to our proposal concerning the deadlines for LSW’s opposition papers and Plaintiffs’ reply papers, and agree that LSW will not file its own motion concerning the class notice, please prepare a joint stipulation and proposed order for our review. Thanks, Jeanette Jeanette T. Barzelay Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655-4346 Fax (650) 745-2866 JBarzelay@kasowitz.com
‐‐‐‐‐Original Message‐‐‐‐‐ From: Shapiro, Jonathan [mailto:Jonathan.Shapiro@wilmerhale.com] Sent: Wednesday, March 13, 2013 10:13 AM To: Perla, Timothy; Brian P. Brosnahan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg; Shapiro, Jonathan Subject: RE: Deposition notices Folks, While we are on the scheduling headnote, 4/8 is rough for me to get to Santa Ana (family/kid conflict). Can we do 4/22 (two weeks)? If bumping it the extra week is really a problem, I could do 4/15 (which is school vacation but still better than 4/8). Thanks, Jonathan Jonathan A. Shapiro | WilmerHale 950 Page Mill Road Palo Alto, CA 94304 USA +1 650 858 6101 (t) +1 650 858 6100 (f) jonathan.shapiro@wilmerhale.com
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Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy Sent: Wednesday, March 13, 2013 10:08 AM To: Brian P. Brosnahan; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ Can we do Nancy in DC? She's from Baltimore so that seems like the closest place that's also simple for us all to get to. I'd be glad to host at our DC office (1875 Pennsylvania Ave), which is not far from National airport. Timothy Perla | WilmerHale 60 State Street Boston, MA 02109 USA +1 617 526 6696 (t) +1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Brian P. Brosnahan [mailto:BBrosnahan@kasowitz.com] Sent: Tuesday, March 12, 2013 5:07 PM To: Perla, Timothy; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices March 28 is fine. Let's do both depos at 9:30 a.m. Thanks, Brian
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Brian P. Brosnahan Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655‐4337 Fax (415) 358‐4278 BBrosnahan@kasowitz.com ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy [mailto:Timothy.Perla@wilmerhale.com] Sent: Tuesday, March 12, 2013 1:33 PM To: Brian P. Brosnahan; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ What about March 22 or 28 for Winings? I haven't confirmed with her yet, but as far as I can tell from our back and forth those would be possibilities. Timothy Perla | WilmerHale 60 State Street Boston, MA 02109 USA +1 617 526 6696 (t) +1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Brian P. Brosnahan [mailto:BBrosnahan@kasowitz.com] Sent: Tuesday, March 12, 2013 2:09 PM To: Perla, Timothy; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Tim, I have a hearing on March 21, but we can do Weinbaum on March 19. Please confirm date and place for Weinbaum and please provide an alternative date for Winings. Thanks, Brian
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Brian P. Brosnahan Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655‐4337 Fax (415) 358‐4278 BBrosnahan@kasowitz.com ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy [mailto:Timothy.Perla@wilmerhale.com] Sent: Tuesday, March 12, 2013 5:42 AM To: Brian P. Brosnahan; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ Following up. I have people trying to hold dates open so please let me know.... Tim Timothy Perla | WilmerHale 60 State Street Boston, MA 02109 USA +1 617 526 6696 (t) +1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy Sent: Monday, March 11, 2013 8:18 AM To: 'Brian P. Brosnahan'; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ Understood ‐‐ trying to accommodate one trip. Winings is unfortunately away in early April. She could do March 21. I know there's a one day gap, but that's the closest I'm coming to back to back. How about that? Timothy Perla | WilmerHale 60 State Street
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Boston, MA 02109 USA +1 617 526 6696 (t) +1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Brian P. Brosnahan [mailto:BBrosnahan@kasowitz.com] Sent: Friday, March 08, 2013 9:29 PM To: Perla, Timothy; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Tim, we could do March 19 and could also do April 4. We would prefer to do Weinbaum and Winings in one trip. Could Winings do April 3 or 5? Brian Brian P. Brosnahan Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655‐4337 Fax (415) 358‐4278 BBrosnahan@kasowitz.com ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy [mailto:Timothy.Perla@wilmerhale.com] Sent: Friday, March 08, 2013 12:04 PM To: Brian P. Brosnahan; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ Still working on Nancy but I heard back from Peter. He has an extensive travel schedule for March, but could be available in Boston on March 19. Could that work for you? If that doesn't work, the best alternative that I have for Peter is April 4. I presume you prefer sooner. Let me know. Timothy Perla | WilmerHale 60 State Street Boston, MA 02109 USA +1 617 526 6696 (t)
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+1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Brian P. Brosnahan [mailto:BBrosnahan@kasowitz.com] Sent: Friday, March 08, 2013 2:02 PM To: Perla, Timothy; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Tim, the 29th will not work. Could we do Nancy on the 25th or 26th? Maybe Peter on the 27th? Brian P. Brosnahan Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655‐4337 Fax (415) 358‐4278 BBrosnahan@kasowitz.com ‐‐‐‐‐Original Message‐‐‐‐‐ From: Perla, Timothy [mailto:Timothy.Perla@wilmerhale.com] Sent: Friday, March 08, 2013 5:15 AM To: Brian P. Brosnahan; Shapiro, Jonathan; Lux, James; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: RE: Deposition notices Brian ‐ We received the deposition notices. I can confirm that we represent both of the noticed witnesses. We do not need subpoenas, and will be glad to work cooperatively on dates and locations (the witnesses do not reside near Boston, but I may be able to have them voluntarily come to Boston). I am waiting to hear back from Peter about dates. I understand that Nancy is not available on the proposed date, but could do the 29th. Would you like to lock that in? Tim Timothy Perla | WilmerHale 60 State Street Boston, MA 02109 USA
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+1 617 526 6696 (t) +1 617 526 5000 (f) timothy.perla@wilmerhale.com Please consider the environment before printing this email. _____ This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately‐‐by replying to this message or by sending an email to postmaster@wilmerhale.com‐‐and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at www.wilmerhale.com. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Brian P. Brosnahan [mailto:BBrosnahan@kasowitz.com] Sent: Wednesday, March 06, 2013 8:11 PM To: Shapiro, Jonathan; Lux, James; Perla, Timothy; Robinson, Andrea Cc: Eugenia M. DiSabatino; Jacob N. Foster; Jeanette T. Barzelay; Charles N. Freiberg Subject: Deposition notices <<Notice of Dep Winings w POS.pdf>> De <<Notice of Dep Weinbaum w POS.pdf>> ar counsel, Attached please find deposition notices for Nancy Winings and Peter Weinbaum. I believe you previously advised us that you represent Mr. Weinbaum. Please let us know whether March 26 is workable for his deposition and please confirm that he will not require a subpoena. Please also advise us whether you represent Ms. Winings and whether a subpoena will be required. If not, please advise us whether March 27 will work for her deposition. Thanks, Brian Brian P. Brosnahan Kasowitz, Benson, Torres & Friedman LLP 101 California Street, Suite 2300 San Francisco, California 94111 Tel. (415) 655‐4337 Fax (415) 358‐4278 BBrosnahan@kasowitz.com This e‐mail and any files transmitted with it are confidential and may be subject to the attorney‐client privilege. Use or disclosure of this e‐mail or any such files by anyone other than a designated addressee is unauthorized. If you are not an intended recipient, please notify the sender by e‐mail and delete this e‐mail without making a copy.
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