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Enron Mail |
Paul:
I received your letter yesterday -- under the circumstances, I would appreciate it if you would draft, execute and forward to me a motion to withdraw prior to your departure on Thursday for Europe. I have not been able to secure other counsel as of this time, but hope to do so shortly. When I am able to find other counsel, I will have the motion to withdraw filed with the court. I would also appreciate it if you could forward to my home my case file along with the family photos I gave to you. If you have any concerns with these requests, please let me know immediately. Thank you. Linda Guinn "paulcooley" <paulcooley@mail.ev1.net< on 05/08/2000 02:58:38 PM Please respond to <paulcooley@mail.ev1.net< To: "Linda R Guinn" <Linda.R.Guinn@enron.com< cc: Subject: Re: divorce Linda: Please see the attached letter. I am also sending to you by regular mail the proposed changes sent to me by your husband's attorney. Paul Cooley ---------- Original Message ---------------------------------- From: "Linda R Guinn" <Linda.R.Guinn@enron.com< Date: Mon, 8 May 2000 08:43:41 -0500 < < <Paul: < <Since I haven't heard from you I didn't know if you had received this or not. <Below is a message I transmitted late last week. < <***************************************************************************** ********************** <I'd like to subpoena Jack's apartment lease and application for Pin Oak Estates. <Can you provide me with some form subpoena and I'll do whatever "leg work" needs <to be done in order to minimize your time. I know time is short for you with <your vacation coming up. I'm hoping Jack signed his lease (and possibly the <application) post April 12. However, I'm afraid he signed the application prior <to the April 12 hearing date, but signed the lease post hearing date. Is this <of any significant relevance? < <Secondly, after we receive the lease and application, I'd like to send out some <requests for production. It doesn't seem as though we're going to be able to <settle this, so I thought we'd be best served by getting as much information <from them as possible. Let me know what you think about this idea. Below, I <have listed a few discovery requests ---- let me know if you think these are <adequate. < <1. Please produce your paycheck stubs from each full-time and part-time job you <have had since January 1, 2000 until the present. <2. Please produce your application for apartment lease at Pin Oak Estates <Apartments. <3. Please produce your lease agreement on your apartment located at Pin Oak <Estates Apartments. <4. Please produce your bank statements from Chase Bank (or any other banking <facility you have) for the months of April and May 2000. <5. Please produce your credit card statements for all credit cards in your <name, both jointly with your wife and solely in your name. <6. Please produce all statements of the stock account in your name with the <brokerage firm, Datek, and any other stock brokerage firm. <7. Please produce your 401K account statement from all such accounts both with <your current employer and with your previous employers. <8. Please produce a copy of your current W-2 as filed with your current <employer(s). < <Like I stated above, we need to get his lease agreement and application before <we ask him to provide it, so he doesn't try to alter the date or anything else. < <Also, I am happy to put these discovery requests in final form or do whatever <you think is best. I hope you understand my need to keep costs at a minimal. <Thanks for your advice. < <Linda < <P.S. In light of your vacation, will there be anyone who can help me while <you're gone? Would you like me to ask my boss to step in as co-counsel? I <don't know if he's willing or not, but I can certainly ask. After all, pride <left me a long time ago. Money is a factor, however, I need representation <while you're away. Let me know what you think. Thanks. - Client, 5-8-00.doc
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