Chase

Open tasks (2)

Decisions (4)

• Exclude pre-receivership amounts (~$480K) from motion demand
  Matt's position that it is not credible to ask the judge for amounts already identified as pre-receivership; those amounts are explicitly excluded
  Apr 1, 12:00 AM
• Use declaration approach as alternative to repeated depositions
  Agreed to draft a declaration and send it unsigned to Chase's counsel to see if it is sufficient to stop further depositions
  Apr 1, 12:00 AM
• Put Neveo up for deposition Friday then pursue evidentiary stipulation
  Decided to have Neveo deposed on Friday and then push for a stipulation that his testimony applies across all matters, to counter Chase's building-by-building deposition strategy
  Apr 1, 12:00 AM
• Present $760K settlement offer to Chase as negotiating position
  The group agreed to convey $760K to Chase's counsel as the opening negotiating position, anticipating a counter in the threes or low fours
  Apr 1, 12:00 AM