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imp82

10/22/21 3:37 PM

#92362 RE: VC3 #92306


75. Carter's claim that Ms. Leane had terminated the Advisory Services Agreement to
'take a job at Technicolor' was blatantly false.
76. In fact, Ms. Leane had taken a position as Technicolor's head ofIP in June of 2017,
roughly a year before Whitman advised her that the case required that the Advisory Services
Agreement be terminated.


79. On February 23, 2020, Ms. Leane texted Mark Raskin, another ofChanBond's (and
IPNav's) attorneys, to discuss Carter's attempt to renegotiate the deal. Raskin responded "I spoke
with him [Carter] briefly. He said he's not trying to screw you out of anything but is worried about
anything af dexting [sic] the case at this point."

"82. On February 27, 2020, Raskin texted Ms. Leane.
83. Raskin wrote "[a]t this point I don't think you need the 'ASA' per se. Just an
agreement that you get paid whatever you were supposed to. I think he said he'd do that."
84. Upon information and belief, the "he" Raskin was referring to in the text message
was Billy Carter.
85. Upon information and belief, Carter had again conveyed his acknowledgement that,
pursuant to the terms of the parties' prior agreement, IPNav was "supposed to" get paid 22% of
the gross recovery."



The whole document is Deirdre saying that Mischon said she couldn’t have her 22% because it would mess up their trial.

If they know they owe her 22%, then they are aware of the waterfall as outlined in the lawsuit.

Mischcon supposedly couldn't find the agreement when she mentioned it in a deposition with the lawyers for the 13 and it would be a problem in discovery, so they convinced her to cancel it with the promise they would draw up a new agreement.

Was that not the whole point of those sections? Their advice is referenced in the agreement. If I'm interpreting this correctly, the question is how did we get to this point and what is their involvement?