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Penny Henritze

From: Don Samuel

Sent: Monday, November 12, 2007 2:51 PM
To: Penny Henritze
Subject: stoufflet status

The various emailsthatIhavesentoverthepastweekdocumenttheprogressthatwemade.To

summarize: (1) I met with Chris on Monday night and Tuesday night. He did no show up for the
meeting scheduled for Thursday night. (2) I met with Randy Chartash and Larry Sommerfeld on
Monday. The plea agreement that they offered, in the end, was as follows: there will be a statutory cap
of five years. The Guideline Calculation results in a low-end guideline of 41 months. We are permitted
to request a Booker downward variance. We can get a SKI. 1 if Chris cooperates. However, the
mere fact that the doctors enter a guilty plea does not mean that we will get a SKI. 1 departure. If the
doctors go to trial and he testifies, he may get a downward departure, or ifhe provides information on
some other defendant, he may earn a SKl.I. The government recognizes that the <;emi-advice of counsel
defense would be a basis for a downward variance, though they are not advocating it. The two co-
defendants' deals result in a guideline calculation of 36 months. The are barred from requesting a
Booker variance, but in light of the concession made to us, the government will allow them to make the
argument, as well. The co-defendants also expect a SKI.I departure. The reason our guideline
calculation is higher is because of one extra point for role in the offense. After negotiating this deal, we
met with Chris and after several hours and a night to sleep on it, he agreed to enter the plea. The
remaining issue is the forfeiture. The government calculates, based on the check registry, that Chris
took out $4.1 million between 2002 and 2003. Oviously, Chris cannot pay that amount. It is also
inconsistent with the amount of money that the co-defendants are required to pay (approximately
$500,000). Chris agreed to meet with his accountant and discuss what money he actually took out of the
company; how much of that money he paid in taxes; and why the co-defendants took so much less (even
under their 50-25-25 percentage agreement). That is how things were left Thursday night. Over the
weekend, Chris suddenly started finding various articles about internet pharmacies in numerous
publications, including government agencies, and he is now talking about the defense that he has. I have
not been able to talk to him, because he does not answer his phone, or return calls. I don't know ifhe is
forwarding this information in order to add to our Booker arguments, or to renew his interest in a trial.
The deadline is Wednesday morning when the plea is scheduled to be entered. Please bear in mind that
Chris blames all his problems on lawyers: Buddy, Craig, Jerry, Arent Fox, Kilpatrick Stockton, Mel
Hewitt, Darin Traub, etc. Ifhe does not receive a very clear message from us about the dangers of trial;
the advantages of this plea; the looming deadline, etc, he will simply add us to his list oflawyers who
failed to properly communicate with him. I propose that we put in writing, immediately, our advice, the
deadline, the dangers of trial, including the difficulty (or impossibility) of mounting an advice of counsel
defense where the lawyers are going to line up, one after the other, and deny having provided any advice
to authorize the conduct, and get him to sign this document. He has had YEARS, to consider this plea.
He is not being forced to consider this at the last minute. I am more than willing to prepare for trial and
will be willing to shoulder most of the work at trial. But he must start talking to us on a regular basis.
He must listen when we talk to him. He needs to show up for meetings when they are scheduled. He
needs to understand what we tell him, rather than conducting relatively useless internet searches about
the current state of the law. And he needs to stop thinking that his valuable advice to the government
(about helping them stop the crimes from occuring) will help him. That was the focus of our attention
two years ago prior to the return of the indictment and we don't need to revisit that old news. The one
thing we must absolutely ensure is that he understands exactly the situation we are in. Otherwise, we
will simply be added to the list of lawyers who don't give him clear and unmistakable advice.

11/12/2007
RE: Decision - But a few more issues I still have - thank you
Sunday, March 30, 2008
11:50 PM

Subject RE: Decision - But a few more issues I still have - thank you Nov 12 2007:
Samuel to Garland
From Don Sa muel
Subject: stoufflet status
To Chri s topher Mi chael Stoufflet
Sent Wednesday, November 07, 2007 9:36 AM 1) The legal advice will be
useful to convince the
The plea would be to the same count of the indictment as Sorbert and Erin. I need to know the financial Judge but its "hard to
situation ASAP. The information about (and from) the lawyers will all be useful to convince the judge to imagine" whether it is
impose a shorter sentence. Whether it is sufficient to convince the jury that you are not guilty of every sufficient to convince
count is hard to imagine. Unless there is some document out there from a lawyer that unequivocally the jury I am not guilty
says, "You are acting totally lawfully", you are simply finding more of the same type of thing we already of "every single count"
have (i.e., "You are engaged in "risky" business which we cannot assure you is lawful, but keep paying us
and we will keep working on this") With Sorbert and Erin pleading guilty (and thereby acknowledging 2) This is misleading
that they knew they were doing something wrong), I think that a trial is very dangerous. What also because we were being
concerns me is that all the lawyers will deny ever telling you anything other than what is in the told, in writing, it was
documents and emails. I don't know much more that we can talk about to help you make this decision. If not illegal. We "keep
you delay much longer, there simply won't be a decision to be made, because there won't be an offer on paying us and we will
the table. keep working on this"
dfs so we remained
complaint and "lawful"
-----Original Message----- was the reason the
From: Christopher Michael Stoufflet [mailto:cms@cmichaelmail.net] lawyers were involved
Sent: Wed 11/7/2007 7:56 AM to the extent they
To: Don Samuel were.
Cc: dlevitt@levittllc.com
Subject: Decision - But a few more issues I still have - thank you 3) "trial is very
Good morning Mr. Samuel, dangerous."
I know I am supposed to providing you and answer this morning. By no means do I want to do anything (I still insisted on trial)
that will cause the government to think of my any worse than what they already do. I understand that
they need to get prepared and time is crucial but this decision is extremely crucial for me too because I 4) "The lawyers will deny
have been set on fighting to the end to prove my innocence. ever telling you"
A couple of quick things -
I am having trouble recalling if we had a Georgia physician working for us in 2002 or 2003. 5) Looming deadline
I also have some additional information that helps in a number of way that I keep coming across.
A decent amount of information that has now surfaced from the attorney's, have never been
previdledged to.
I should have some fianiancals this morning for my CPA and will call you when I get them.
We have never received a complaints about anyone being injured, from our business, no lawsuits, etc....
After we closed, I found out Erin was engaged in earning income from helping people get set-up in the
"online pharrmacy business"
Is it possible to see the plea agreement?
Perhaps I may have missed this part, but what would I be pleading guilty to? Conspiracy like Sobert and
Riggins?
I know you are probably getting tired of all of these things I continue to bring up but I feel that they are
important in 2 ways. They reflect my actions not to engaged in any illegal acititivity but what measures I
took to avoid to doing anything wrong.
Can you please request a little extra time, even by the end of the day today would possibly help me in
making this type of decision.
I will call david around 11 if that's OK.
Thank you Mr. Samuel,
-Chris Stoufflet

Garland & Samule Page 1

RE: Request To Rectify the Misinformation
Monday, March 31, 2008
12:44 AM

Subject RE: Request To Rectify the Misinformation

From Don Sa muel
To CMS | CMi cha el Group
Cc Ed Ga rl and
Sent Thurs day, February 07, 2008 6:29 PM

I never said, “It was illegal and you knew it.” I never said that, because I don’t have any evidence that
establishes that to any degree of certainty. What I said, and what I will say again is this: IT WAS
ILLEGAL. Whether you knew it or not is a different matter. But it WAS illegal, because the judge in our
case has declared that it was illegal and we have to live with that decision. So we start with the
proposition being told to the jury in your case that you were committing a crime, every day, for a couple
years. You made a lot of money through the commission of what we now know to be illegal acts. You
had doctors who were not seriously acting as doctors in any meaningful sense of the word, because they SAMUELS NOV 12 2007 EMAIL
were writing prescriptions faster than they could sign their name without ever seeing a single patient. TO GARLAND DISCUSS THESE
The next question is whether you can assert that you shouldn’t be found guilty – even though you were EXACT ISSUES :
committing a crime -- because you didn’t realize you were committing a crime. That is where the rule
“ignorance of the law is no defense” comes in to play. I may engage in all kinds of conduct that is illegal, 1) Lawyers are required to give
without realizing that it is a crime. That doesn’t make it legal. If that is all it took to make something "clear and unmistakable advice"
legal, we would have everybody charged with a crime simply saying, “I didn’t realize it was a crime.” and that’s' what I believed I was
The only exception to the rule, “Ignorance of the Law Is No Defense” is in cases involving complex laws receiving.
(such as tax, securities, etc) where the courts have carved out an exception for people who seek the
advice of an attorney and are given clear advice that their conduct IS LEGAL. The problem in our case is 2) Emphasizing "catastrophic"
twofold: (1) I don’t know whether the judge will decide that the drug laws (internet pharmacy laws) are [I still insisted on going to trial]
so complex that the exception to the rule even applies. I think it should, but I can’t tell you with any
degree of certainty that the judge will decide that the drug laws are that complex; (2) Even if the
exception does apply, I don’t know if letters from lawyers that say, “BEWARE, BEWARE this is “Risky” 3) Enormous risk
this is something that you might get prosecuted for” qualifies as “THIS IS PERFECTLY LEGAL”.
Let me emphasize again, I am not telling you, and Ed is not telling you, that you are absolutely going to
lose this case. The problem is, that if you do lose, it is catastrophic. The plea we have been offered is a 4) "given the lack of support from
settlement, like all lawsuit settlements, it is not perfect. It is intended to eliminate the risk of a the lawyers, who will NOT say
catastrophe. If you are not scared of the risk, or, as a matter of principle, can’t stomach the thought of that they told you “This is legal
pleading guilty, than as long as your eyes are open and you understand the enormous risk and conduct” – that you are relying,
understand the law as I am explaining it to you, than your decision to go to trial is a decision you have instead, on your belief, that you
the right to make. Ed and I both the think the risk is enormous and given the lack of support from the were “entitled” to be told in
lawyers, who will NOT say that they told you “This is legal conduct” – that you are relying, instead, on unequivocal language that the
your belief, that you were “entitled” to be told in unequivocal language that the business was business was illegal."
illegal. There is no law, that I am aware of, that says you are “entitled” to be told in unequivocal
language that your behavior is illegal before you can be prosecuted for a crime. Again, the example with 5) "There is no law, that I am aware
the Enron defendants: they had lawyers and accountants reviewing everything that they did – and of, that says you are “entitled”
cautioned them –but nobody ever screamed, “CRIME, CRIME, CRIME” And yet, they were sentenced to to be told in unequivocal
virtually life sentences. language that your behavior is
I am not laboring under any misconceptions from the Case Map or any other lack of information. I illegal before you can be
believe that I have read every single email/letter and document in this case. If you think I am missing prosecuted for a crime"
some incredibly important document, bring it over. But documents created in 2007 are not of any (It may not be a "law " but a
relevance. The only thing that would make a substantial difference in my opinion is a document from a lawyer is required inform their
qualified lawyer who says, “I have reviewed the business that you are operating and in my opinion, it is client of what is allowed and
legal to dispense drugs from an Internet Pharmacy without a doctor ever seeing the patient.” what is forbidden)
dfs

From: CMS | CMichael Group [mailto:cms@cmichaelgroup.com]

Sent: Thursday, February 07, 2008 2:53 PM
To: Don Samuel
Cc: Dianna Cole; Penny Henritze
Subject: Request To Rectify the Misinformation

Good afternoon Mr. Samuel,

Thank you for your time yesterday as it allowed me to hear your concerns and also have a
better understanding of why you and Mr. Garland have suggested that I enter a plea.

Please allow me to clarify some very important issues that have been distorted.

I agree with you that a decision needs to be made soon as trial is set for March 10th. In order for
me to be able to make a good decision as to whether to go to trial or enter a plea, I need to
have a better understanding of everything than I do now. This means I need to feel that you
have been presented all of the facts and based on our conversation yesterday; I felt at times
that we were talking about 2 different cases. In my discussions with you and Mr. Garland I get

Garland & Samule Page 1

that we were talking about 2 different cases. In my discussions with you and Mr. Garland I get
lost somehow, and somewhere from the time everything was great with my business, there
were no problems and nothing I was doing was illegal (Kilpatrick’s steadfast position) to
everything being my fault and I’m operating an illegal business. There is a big cloud of confusion
here and that wasn’t the case while were in operation.

The miscommunication of the facts are somewhere between the time where I re-start
operations with the blessings of a Federal Agent, Federal Judge, in-house attorney with
Kilpatrick’s full knowledge and involvement, a former federal Prosecutor who specialized in
criminal law, with the knowledge of the Federal Government, Ms. Sandy Strapoli and her team,
continuous State pharmacy board inspection approvals, DEA knowledge, and the addition of
more legal counsel, including Arent Fox………
On October 24, 2003 – Mr. Parker emailed us the following: “You all should note that the DEA
takes the position that any doctor who does not physically see his/her patient cannot prescribe
any controlled substance. The hammer will come down on Vince very soon.”
Besides the letters and that email - please read below -
 Oct. 20th 2003, Buddy Parker – approves “eScripts.MD’s continued commitment to lawful
and ethical business practices”
“rest assure that we continue to remain in compliance and keep up with the ever
changing regulations. We are constantly working with our outstanding team of legal
experts to ensure and protect our position in the industry, and most important, our plans
for the future”.
 Oct. 23, 2003 – Allison Shuren – “You were right to check. Things are definitely heating up,
and you are trying to make sure you are doing everything right”.
 Oct.27, 2003 – Federal Government - Carmen Catizone, executive director of the
pharmacy board association. “The local governments actions add a patina of legitimacy to
the purchases and this “sends the wrong signal” to owners of rouge pharmacies”.
“They’re seeing the governments saying it’s okay to break the law and we’re *state and
federal government regulators+ not going to do anything.”
 November 17, 2003 that “the activity has not, I repeat not been found to be “illegal” per
se. It is obvious that the DEA contends that it is illegal and one or more judges may
conclude ….”
 Nov.6th, 2003 – both Allison Shuren and Mr. Parker acknowledging that “we have always
worked closely with our attorneys regarding the legalities of this industry.”

November 3rd, 2003 – Business stopped. We were called into a meeting and advised to stop
offering patients the ability to request a prescription for controlled substance.

Operating An Illegal Business: In yesterday discussions you mentioned it was an illegal business
and I knew that. As you can see from the above statements, that is incorrect.
There is a serious breakdown of communication as to what actually happen. I feel that you and
Mr. Garland have already draw the conclusion that it was illegal but as you can see from the
documents, no one else had ever viewed it as illegal, except the DEA in Oct. 2003.
Once again, if we can please clear up that issue, I believe you will see things as they really were.
I noticed you were looking through the Case-Map yesterday. I am not sure you received my
message about the CaseMap but David Levitt has the majority of the information mislabeled
and from what I read is almost all incorrect.

The Arent Fox letters: as important as they are, more so now than ever before, in trying to
think back I can honestly say that barely even remember the letters being referenced much less
even mentioned after we received them. The part I was involved in was the implementation of
the implementation of the new components we were to implement, continue our efforts to
locate doctors in every state to help with compliances issues and to keep continued efforts on
the new business model.

Advice of Counsel: The letter I was not aware I was supposed to have; the “Perfect Advice of
Counsel” letter.
I had never seen nor received or much less knew such a letter even existed, as my other
business never required much legal input. In this business, when I sought and received advice,
this is the way things were explained to me: We cannot find anything with the business that is
illegal, but it is an area that you must stay “on top of things” because it is a growing and
“Evolving business.”

My request: Will you please allow me opportunity to provide you the facts and supporting
documentation and explain what happen without the preconceived notion that it was illegal
and I knew it.

I hope I was able to provide you with some information that will cause you to take a second

Garland & Samule Page 2

I hope I was able to provide you with some information that will cause you to take a second
look at things as I am speaking the truth and have the documentation to support what I am
saying.

It is approx 2:50 and I can continue working on everything here and be prepared to meet you in
the morning or if you still want to meet today, just let me know. Whatever is better for you.
Thank you.

Respectfully Submitted,
-Chris Stoufflet

Garland & Samule Page 3

RE: RE: Monday's meeting
Friday, October 10, 2008
12:16 PM

Subject
RE: RE: Monday's meeting
From CMS | CMi cha el Group
To 'Don Sa muel'
Sent Sunday, August 03, 2008 8:50 PM

Hello Mr. Samuel.

Thank you for getting back to me. 3 sounds great and I will get there earlier if you
would like discuss something's with me.
I just ask that you respect my position and my convection to do what is right and
it begins with being able to tell my side of the story. I have been dealing with this
for 8 years sir, and the last 6 have been "life-draining" but also character building
and spiritually rewarding even though I have been very much alone.

I am grateful to finally have this opportunity so they may hear what it is I have to
say. I am not expecting anything more from them but to just really LISTEN.
Tomorrow is a chance for me to begin "righting the wrongs" and it starts with me.

Mr. Samuel, I realize we have our differences, and that we are both are entitled to
have opinions about the case, but our opinions I the end, really will not matter.
What will matter is of I did what was right and if they governed themselves
ethically and within Rules of Professional Conduct.

Thanks for offering to be there tomorrow and if you would like to meet before,
please let me know when and where.

Sincerely,
-Chris

-----Original Message-----
From: Don Samuel [mailto:dfs@gsllaw.com]
Sent: Sunday, August 03, 2008 11:22 AM
To: cms@cmichaelgroup.com
Subject: Re: RE: Monday's meeting

As of.now, it is 3:00. At the US Attorney's office. If they change the time, how will
I let you know? Do you want to talk before then? Do you want me to participate,
or just be a spectator? I will be in court at 10:00 and may stay downtown until the
meeting.
Don

----- Original Message -----

From: CMS | CMichael Group <cms@cmichaelgroup.com>
To: Don Samuel
Sent: Sun Aug 03 10:34:45 2008
Subject: RE: RE: Monday's meeting

What time is the meeting tomorrow?

Thank you,

-Chris

From: Don Samuel [mailto:dfs@gsllaw.com]

Sent: Friday, August 01, 2008 1:26 PM
To: CMS | CMichael Group
Subject: RE: RE: Monday's meeting

1. The prosecutors want to ask you about Dr. Hollis in particular and the history of
his involvement in the company.

2. I agree with your statement regarding “Side 1”. I think your statement of “Side
2” is not exactly accurate. I don’t know that I have ever said “you should have
known” – I don’t think that is the correct way to phrase the situation. I think that
a better way to describe the situation is that you were receiving warning flags
from some lawyers (particularly Arent Fox and some of the lawyers at Kilpatrick)

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from some lawyers (particularly Arent Fox and some of the lawyers at Kilpatrick)
and that you decided that a “warning” was not equivalent to a stop sign. I don’t
mean to be silly about it, but I think that is more accurate than “you should have
known.” As far as the advice to plead guilty, that is more complicated. My
greatest concern has always been that the court would decide that relying on a
lawyer IS NOT A DEFENSE at all to this type of crime. You may say that that is not
justice and I don’t necessarily disagree, but that may be exactly what the law says.
That is the great risk. If the court were to decide that relying on a lawyer’s advice
1) "great risk"
is not a defense, then we would not be able to introduce any evidence relating to
the lawyer’s advice. The issue is not whether the lawyer’s gave you insufficient or 2) He acknowledges the
inaccurate advice. WE ALL AGREE THAT THAT HAPPENED. The question is whether lawyers advice was
inaccurate or insufficient
that is a defense to the charge. And remember, the government knows about the but takes no action to hold
advice from Arent Fox and Traub and Parker and Gillen and Kilpatrick and the them accountable.
issue with Scofield and THEY WERE THE ONES WHO FILED THE MOTION TO
EXCLUDE ALL THAT EVIDENCE AS BEING IRRELEVANT. That is what we were filing 3) Judge Cooper did decide
and rule in my favor!
motions about the week before the scheduled trial. We were the ones fighting to
get that evidence admitted; the government was fighting to keep the evidence 4) He acknowledges vital,
out. And, of course, the judge never decided the issue. favorable evidence
and fails to subpoena it
3. Regarding the three items you want to retrieve. I can issue subpoena, but a 5) "If as he fears"….it was ruled
subpoena in a criminal case can only seek to have the document/tape etc and determined that the
returned to court for trial or the hearing. We have no trial or hearing scheduled, "Advice of Counsel" was
available to me
so I cannot issue a subpoena right now.
as a defense.

4. I have produced everything to the government. I don’t think that anything else 6) At "sentencing" is not the time
will change with them. However, I think the court will be very interested in these to argue innocence…..
materials when he decides what to do at sentencing. If, as I fear, the information
is not admissible at trial to prove innocence, it is still absolutely and positively
admissible at sentencing to prove why no sentence is appropriate. Does that
make sense?

5. I am on your side. I am not defending, at any time or place, Parker, Gillen,

Froelich, Arent Fox; Traub, or anybody else. I am not protecting them. I am
committed to bringing out into the open, all the letters and emails that led you to
believe that the conduct was not illegal. I have done that in the past. I will do that
in the future. I have never hesitated to do that. I am on your side and there is no
equivocating about that.

Don

From: CMS | CMichael Group [mailto:cms@cmichaelgroup.com]

Sent: Friday, August 01, 2008 12:08 PM
To: Don Samuel
Cc: Ed Garland
Subject: RE: Monday's meeting

Hello Mr. Samuel and Mr. Garland,

I will begin by addressing the issue of me being disrespectful.

If you think that I have become disrespectful in my communications, I apologize
because I have always strived to conduct myself in a very respectful manner, even
if I am being mistreated and FALSELY ACCUSED. All of my communications for the
past 2 years have been extremely respectful. I am now at the point where I feel I
have been very much mistreated and disrespected and I am exhausted in my
efforts to have you accept the truth.
And month after month I have presented you one episode after another of the
wrongdoings of Parker, Gillen, and Froelich and I had to watch both of you choose
to “turn a blind-eye” to such serious issues. I can tell you that has only intensified
matters with me.

In response to everything, here is the unfortunate position I face and how I see
things.

Because of all of the avoidance I have received in addressing the serious matters
in this case, it seems as you and Mr. Garland have been able to take 2 sides SIDE
1) You both have agreed and told me that what had happened was wrong and
that the attorneys didn’t do their job, they didn’t make things clear.

SIDE 2) You both have agreed and told me to plead guilty because the laws were
changing around me and I should have known.

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changing around me and I should have known.

So I ask you, where is the justice in this advice?

And for a moment, lets remove the option to plead guilty to avoid going to trial
[because that does nothing to correct the situation anyway]

So I would like to know what are your suggestions to rectify the matter of the 2
sides above?

Here is another BIG PROBLEM that I see and it is this way because you have done
nothing to correct it, and by not correcting it, it only has made matters worse.
That is whenever I have presented FACTS that discredits Parker Gillen and
Froelich’s position, the truth is compromised…..

Here are a few recent examples:

>The Joint Defense Agreement – I am provided deterrents from getting it (I asked
that it be subpoenaed. appreciate you asking them for a copy but it is too
important to rely on them to provide a copy at their leisure - time is of the
essence) > Recordings of Froelich – I also asked that it be subpoenaed but again I
am provided deterrents from receiving it.

> The “Conflict of Interest” issue - here again, just more deterrents most of them
being false.

These are only three examples of the many problematic issues that reflect that
what is in my best interest is not being upheld.

I have tried and tried to get you and Mr. Garland to do what is right and correct
the issues I have brought to your attention in my 26 -page letter. Much of it would
entail exposing the wrongdoing of Parker, Gillen, and Froelich. That has yet to
happened and in fact I am only met with more resistance and I would be a fool to
believe there were any plans to do anything about it. Enough time has passed to
have at least put forth some effort into correcting some of the issues.

My understanding of your email Mr. Samuel is that you feel that you already
presented everything to the government and nothing more will change anything.
Is that a fair statement?

So a question that needs to be answered is whose side are you and Mr. Garland
on.

And the answer cannot only be in words, it must be with action. I will not allow
what has happened up until this point, continue to happen. I cannot have
someone neutral representing me, as no middle ground exists here, so being
neutral, is being against me.

I am sure you have heard the statement that “the truth is piercing and sharper
than any two-edged sword” and because of that, the truth is going to be
extremely painful for those who have chosen to be untruthful. That is not a
threat, it’s the TRUTH!
If you and Mr. Garland are not willing to stand with me and expose the truth and
do so to the degree that it is UNDERSTOOD, then I would appreciate your
assistance in finalize matters with me.

I have no material things left, so I cannot hire another lawyer, but need to make
whatever arrangements necessary so I have legal counsel present for my meeting
with the government on Monday.

Everything I have written, I have done with no ill intentions as I have accepted
things as they are.

Sincerely,

-Chris Stoufflet

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Please see below:

From: Don Samuel [mailto:dfs@gsllaw.com]

Sent: Tuesday, July 29, 2008 1:08 PM
To: CMS | CMichael Group
Subject: Monday's meeting

Chris: Please call me so we can discuss the timing, place and agenda for Monday’s
meeting with the prosecutors. The prosecutors called me and wanted to let us
know that they wanted to ask some questions about different matters and I
wanted to alert you to these issues ahead of time.

[CMS] OK – Do you know what this is in regard to because I want to make sure I
am prepared and that may mean I need to provide them some supporting
documentation, I will do so. I am planning on answering ANY questions about
anything.

Also, please, please, please, do not contact witnesses (including indirectly,

through other people, including Riggins and Sobert).
I answered this yesterday.

may be considered by the court to violate bond conditions. Both Froelich and
Gillen called to complain (because their clients complained to them).
[CMS] answered this yesterday.. If either of them contacts the prosecutors, they
may consider this a violation of bond and try to revoke your bond.
[CMS] answered this yesterday. I have asked Gillen and Parker for any and all
copies of any joint defense agreement that existed at any time and they said that
they would look and send me a copy of whatever they find.

[CMS] Addressed above and by your answer I assume there will be no attempt to
file a Motion produce the recordings, the JDA and the “Conflict of Interest” issue
either.

I have provided you all the reasons why on numerous occasions.

My cell phone is 404-697-9400. Otherwise, call me at the office.

Don

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