Hello Julia,

What follows is a rough outline of the information included in this folder.




This is how I will reference documents:

We have 2 batches of file disclosures, one from us and one from the opposing counsel:


Dulberg Document Disclosure I will abbreviate as (ddd)


Popovich Document Disclosure I will abbreviate as (pop)



If I am referencing page 289 of the Popovich document disclosures,  I will abbreviate as (pop 289).


The opposing counsel has released one "smoking gun" document that we've never seen before.  It is (pop 192).  Paul never gave Mast authorization to make this offer.  We have ample evidence that Paul never authorized the offer made in (pop 192) and he knew nothing about it until seeing it last week.  Note that it is not in the box of files we gave to you.  It is not in the box of files that Mast gave to Paul when Mast withdrew from counsel.  Also, the Baudin law firm and the Gooch law firm never saw this document.


In this folder I include the following files:



missing_files.txt

This gives a list of documents that I spotted as missing from (ddd) and (pop).  The list is not complete but these missing files are important and the opposing counsel should be compelled to produce them or describe in detail why they can't.

Some files are missing from (ddd) because they were not given to Paul by Mast when he withdrew counsel, so they were never given to the Baudin law firm and therefore never made it to the Clinton law firm.

I explain why I know they are missing when it is not obvious in the file.





timeline_of_mcguire_settement.txt

This gives you a rough timeline of events leading to Paul accepting a $5,000 settlement from the McGuires.  Since we were never able to see (pop 192) until now, we never understood the details of how Mast tricked Paul into such a small settlement.  The fact that Mast initiated the settlement process through (pop 192) without Paul's knowledge or permission is proof that this case is about more than Mast's negligence.  It is about willful intent or malicious intent to deceive his client.

Of course you will need convincing proof that (pop 192) was initiated without Paul's knowledge.  We have that proof.  As I fill in the timeline more and more, the evidence will be stronger and stronger.







questions_for_mast.txt

Here I put together a series of questions that are crafted to pin Mast down in such a way that he must explain what he did.  He should be compelled to explain why he did what he did.

The questions, of course, are just a guide.  We have no desire to tell you how to do your job.  You will know how to phrase questions better than us.  But no matter how the questions are phrased, the points addressed in these questions are important.  It would be nice to see Mast be compelled to address some of them for the first time in 6 years.





REFERENCE INFORMATION





ddd_table_of_contents.txt

(ddd) consists of close to 1500 pages.  I made this table of contents to help Paul and me find certain documents easily within the mound of files.  If it helps you, good.  If not just ignore it.





pop_table_of_contents.txt

This helps us find our way around close to 2500 pages of documents.  For you if you want it.





Folder: Lawyers Emails by date

The emails in (pop) and (ddd) can be a real headache to look through.  This folder helps Paul and me see the streams of email exchanges as they happen month by month.  We find it useful.  It is yours if you want it.  If not, please ignore.

Within these files I reference emails by using this folder and using the form (email: folder_name, file_name).  

For example, the reference (email: 2013 10, Mast2-219) should be easy to find in folder 2013 10.  This folder contains emails from October, 2013 and each email stream is given a separate name.







Thanks.  We will make it our business to know these files and documents intimately.  Please let us know if we can help you locate something, explain anything, or dig up any evidence.  As you can see in the case of (pop 192), locating and understanding the context of a single document can make a huge difference.  It seems obvious to me that Mast tried to hide documents.  The Popovich law firm is still hiding the Gagnon interrogatory answers and the documents they requested from Gagnon and the McGuires.

If there is anything we can do to help, just ask.