WORKPRODUCT SLASH LATTICE - ATTORNEY EYES ONLY - Andrew G. Watters, Esq.
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Date: Fri, 23 Jul 2021 15:21:52 -0700
From: AGW via Slash <apache@justice.slash.law>
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Date: Fri, 23 Jul 2021 15:21:52 -0700
From: AGW via Slash <apache@justice.slash.law>
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Andrew G. Watters (AGW) email url



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WP SL AGW LAWFIRM

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CRITIC TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2021-01-19 13:47 PST by AGW in Doe v. Roe

AGW→LT: Review statement of decision immediately and calendar deadlines.

Case alert: trial court has issued its statement of decision following the court trial of January 15, 2021. Client is exonerated in full. Analysis reveals the court disbelieved the portion of Plaintiff's testimony that related to punitive damages, however, the ruling on the summary adjudication motion was still critical. Statement of Decision [PDF].

Tags: AGW LJ LT Decisions

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ROUTINE TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2020-12-23 16:24 PST by AGW in Doe v. Roe

AGW→LJ: Prepare letter to opposing counsel regarding issue of punitive damages and settlement offer regarding same. Figure depends on OPC's latest thinking on this issue. Last demand was $1.3 million. I think if we give them $750,000 they will go away.

Tags: AGW LJ LT Letters

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PRIORITY TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2020-12-29 13:01 PST by AGW in Doe v. Roe

AGW→LT: Prepare deposition summary of Kamal's deposition

I would like a page-line summary of Kamal's deposition for use in a possible appeal Consult with LJ as appropriate since she took the deposition. Transcript [PDF].

Tags: AGW LJ LT Paralegal

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URGENT TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2021-01-06 07:48 PST by AGW in Doe v. Roe

AGW→LT: Calendar deadline for post-trial documents

Trial was on January 4, 2021 and the court announced his tentative decision that day. Statement of decision should follow any day now. I need you to calendar the stated deadlines for post-trial supplemental briefing following the tentative decision.

Tags: AGW LJ LT Calendar

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ROUTINE TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2021-01-08 13:19 PST by AGW in Doe v. Roe

AGW→LT: Summarize latest supplement document production

We received even more supplemental documents, Bates no. DOE010345-11756. I don't have time to look at all of these with the trial having just completed. Please prepare a summary in the usual style.

Tags: AGW LJ LT Paralegal

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PRIORITY TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2020-12-29 13:01 PST by AGW in Doe v. Roe

AGW→LT: Revise deposition summary of Jim's deposition

Thanks for doing the page-line on Jim's deposition. But I need a little more analysis on pages 78-120. I think those are key sections and you need to break it out in more detail with links to the key documents he references. Transcript [PDF].

Tags: AGW LT Paralegal

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URGENT TASK

WP SL RICHARDROE DOEVROE REL TO CLIENT


2021-01-09 06:47 PST by AGW in Doe v. Roe

AGW→LJ: Research issue of malice as affecting liability of a corporate officer and corporation.

Is intentional defamation dischargeable in bankruptcy? Hinges on whether there was willful and malicious intent in making the false statements. Please review the complaint again and prepare a 2-3 page research memo/report to the client concerning dischargeability of a defamation judgment in bankruptcy. I need to get this to the client before the statement of decision comes out.

Tags: AGW LJ Research

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WP SL PUBLIC WORKAREA

SZS Notes.docx

AGW - profit and loss.pdf

SZS - Closing Statement.docx

SZS - motion to dismiss.pdf
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