Thanks Joe.  Please send us the retainer agreement, and you should include a retainer payment for the amount you anticipate being needed for your review of the documents and to get to the point where we can disclose you as an expert.  We don’t need an affidavit.

 

 

 

Ill do it if Bud is unavailable to do this. Let me know what you need. I suspect a retainer agreement which I can send later and you can draft up any affidavits or disclosure notice required for me to sign.

 

 

 

Thanks Joe.  Our client does not have title insurance, so there is no company involved on our end.  The defendants may have title coverage, but if they do, we don’t know who the insurers are.

 

 

 

 

Wilson. We did a current owner on this back in 2014 and a few years ago we were asked to search it and I declined (which I rarely do) as the customer (a title insurance company for a claim) sent me hundreds of pages of ancient and vague docs. I can’t put my hands on that info but I have a few other places to look. Obviously, others were looking at it and declined. I do find the plaintiffs pro se complaint a classic. I can likely do the testimony under two conditions: 1. I will agree to follow Bud’s theory after a review of the docs to form my own opinion and be sure I agree. It seems all the leg work was done and both parties performed exhaustive and extensive research. Anymore additional research is not likely to yield any further helpful information its down to the trier of fact now; 2. I would like to know what title insurance company is on the hook for this.

 

Let me know thx.

 

 

 

Joe,

 

Nice to meet you over the phone. As discussed, attached are Bud Harvey’s affidavit and expert disclosure, as well as a copy of our summary judgment brief for context. Let’s plan to schedule a call when you’ve had a chance to review, and please send us a quote for a retainer—it will likely be the client’s preference to pay your full retainer all at once.

 

Wilson

 

Wilson Carroll | Attorney | Cohen and Wolf, P.C.

1115 Broad Street | Bridgeport, CT  06604 | P: 203.368.0211 | F: 203.337.5513

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wcarroll@cohenandwolf.com | www.cohenandwolf.com

 

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