EFTA01790173.pdf

From: Martin B. O'Connor II < Sent: Wednesday, December 10, 2014 8:07 PM To: Jeffrey E. Cc: Peggy Siegal; georgej@gtlaw.com Subject: Re: Attorney-Client Privileged Communication 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." <jeevacation@gmail.com <mailto:=eevacation@gmail.com» 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.=br> 12:35 PM, Peggy Siegal <=pan dir="ltr"> <mailt > wrote: What's going on. I don't understand. It feels like Gary does not have th= money to pay me...which is exactly what I was saying for three years. He is a thief. From: Martin B. O'Connor II [mailtoa I Sent: Wednesday, December 10, 2014 10:10 AM To: georgej@g=law.com <mailtereitejftelevreess-ggetaget@stievreern <mailto:W >; 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 therea=ter reach out to Jamie. M EFTA_R1_00117787 EFTA01790173  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 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 confident=al and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are no= the intended recipient, please contact the sender by reply e-mail and des=roy all copies of the original message. Please be advised that based on current IRS rules and standards, the ad=ice contained herein is not intended to be used, nor can it be used, for t=e avoidance of any tax penalty that the IRS should assess related to this matter. That said, please do not h=sitate to call me if you have any further questions regarding this matter.=/font> ent: Tuesday, uecember To: Martin B. O'Connor II; eaw , . O.MJI Subject: Attorney-Client Privileged Communication Martin and Peggy As I mentioned to Martin wh=n we spoke this morning, Ms. Dyce advised me yesterday evening that Gary h=s been working diligently to obtain financing to pay the $150,000 part of the payment due Peggy under the proposed agreement. As yo= can see from the e-mail below, Gary hopes to have an answer regarding fin=ncing today. She has not wanted Gary to sign the agreement when Gary is st=II 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). 2 EFTA_R1_00117788 EFTA01790174  Therefore, she advises me t=at Gary is prepared to make immediate payment of the $426 but needs =ore 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, =ubject to Peggy's approval, is to revise the agreement to provide that G=ry will make immediate payment of the $426 by wire and give him 45 or 60 days to obtain financing for the $150 a=d tell Ms. Dyce that this has to be wrapped up this week otherwise Peggy w=ll seek her remedies in court. I will let you know if I he=r from Ms. Dyce regarding the financing today. I doubt it. Jim James R. George Shareholder georgej@gtlaw.c=m <m. www.gtlaw.com <http://www.gtlaw.com/> <image001.jpg> From: Dyce, Jamie =. Lmailtc >1 Sent: Monday, December 08, 2014 5:33 PM To: e, James R. Shld-FTL-LT Cc: om> 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. 3 EFTA_R1_00117789 EFTA01790175  Jamie R. Dyce<=pan style="FONT-SIZE:7.5pt;FONT-FAMILY:"Arial","sans-seri=";COLOR:#11497d"> Associate Duane Morris LLP 1540 Broadway SIM www.duanemorris.co= <http://www.duanemorris.com> In compliance with U.S. Treasury Regulation=, 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 (0 avoiding tax penalties or (ii) promoting, mar=eting or recommending to another person any transaction or matter addresse= herein. Sent: Monday, December 08, 2014 3:53 PM To: Dyce, Jamie R. Subject: RE: Call Today YEs From: Dyce, Jamie =. [mail Sent: Monday, December 08, 2014 3:53 PM To: George, James R. (Shld-FTL- Cc. Subject: RE: Call Today I need a few, can we do 4:3=? Thanks. Jamie R. Dyce<=pan style="FONT-SIZE:7.5pt;FONT-FAMILY:"Arial","sans-seri=";COLOR:#11497d"> Associate Duane Morris LLP 1540 Broadway New York, NY 10036-4086 4 EFTA_R1_00117790 EFTA01790176  www.duanemorris.co= <http://www.duanemorris.com> In compliance with U.S. Treasury Regulation=, 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, mar=eting or recommending to another person any transaction or matter addresse= herein. Sent: Monday, December 08, 2014 2:24 PM To: Dyce, Jamie R. Cc: obrateaut=pwaSsaliseitena> Subject: FW: Call Today Jamie Martin asked that I speak w=th you this afternoon as you suggested. Does 4:00 p.m. work with your sche=ule? Jim From: George, Jame= 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 5 EFTA_R1_00117791 EFTA01790177  From: Dyce, Jamie =. [manta' , e / >1 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 I'm sorry, I cannot do to=ay. Monday afternoon? Jamie R. Dyce<=pan style="FONT-SIZE:7.5pt;FONT-FAMILY:"Arial","sans-seri=";COLOR:#1.1497d"> Associate Duane Morris LLP 1540 Broadway New York, NY 10036-4086 jr-elveteckiaaemer4s7c-em-4cnailt4a4r-elyeegiikianemer-r-isycecaa www.duanemorris.co= <http://www.duanemorris.com> In compliance with U.S. Treasury Regulation=, 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, mar=eting or recommending to another person any transaction or matter addresse= herein. From: Martin B. O'=onnor II [mailto: Sent: Friday, December 05, 2014 2:47 PM To: Dyce, Jamie R. Cc: Jim George; Pat Zwarycz Subject: Call Today Jamie, Could we have a call today at 5:30 p.m.? I have included our=dial in details - <tel:1-888.363.4734> — Access Code 4236591. Please reply all.4=pan> 6 EFTA_R1_00117792 EFTA01790178  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'C=nnor is for the sole use of the intended recipient(s) and may contain conf=dential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the in=ended 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, t=e advice contained herein is not intended to be used, nor can it be used, =or the avoidance of any tax penalty that the IRS should assess related to this matter. That said, please do not hesitate to =all me if you have any further questions regarding this matter. For more information about Duane Morris, please visit http://www.DuaneMorris.com <https://ur=defense.proofpoint.com/v2/url?u=http- 3A www.DuaneMorris.com&d=AwM=Ag&c=Uk4MC68c_p3FA5jX7N-Q91WDvpli5Y9kf- 6DmZwtkEl&r=lqaxHlobFrC=1ZjXTLmvq-XQ54-3vnWu_Aa10Rq_gx4&m=DKfW-tXlApo_lnJJnXzIS- V_N0G7JJGdZa=8uaLNIEg&s=ecC7yGnwTHG8PLmmheTu8fd2jrCTvamrok6wB8Yu_cE&e=> Confidentiality Notice: This electronic mail transmission is privileged and=confidential and is intended only for the review of the party to whom it i= addressed. If you have received this transmission in error, please immedi=tely return it to the sender. Unintended transmission shall not constitute waiver of the attorney-client or any oth=r privilege. 7 EFTA_R1_00117793 EFTA01790179  If you are not an intended recipient of confidential=and privileged information in this email, please delete it, notify us imme=iately at postmaster@gtlaw.=om <mailto:postmaster@gtlaw.com> , and do not use or disseminate such information. 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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 8 EFTA_R1_00117794 EFTA01790180