From: Valeria Chomsky
To: "jeffrey E." <jeevacation@gmail.com>
Cc: Noam Chomsky
Subject: Fwd: Legal Memo Regarding Distribution Standards
Date: Wed, 06 Dec 2017 22:20:26 +0000
Attachments: Chomsky
_Memo_re_Carol_Chomsky_Marital_Trustsianalysis_of discretionary_distribution_standa
rd)_-_2017_(00667474xA4627).pdf
Inline-Images: image001.gif
Forwarded message
From: Deborah Pechet Quinan
Date: Wed, Dec 6, 2017 at 10:03 AM
Subject: Legal Memo Regarding Distribution Standards
To: Noam Chomsky , Valeria Chomsky
Dear Noam and Valeria,
Attached is the memo we have prepared addressing the above-referenced issue. Please note that as there may be
litigation in the future on this issue, we have marked the memo as "Privileged and Confidential Attorney Client
Communication and Work Product". Generally, attorney-client communications are protected from discovery in
judicial proceedings. The privilege is lost, however, upon disclosure or dissemination to a third party. This
means that if you share this memo with Richard Kahn or with anyone else who is not your attorney, the memo
will be discoverable and adverse parties will have access to our arguments and analysis. While there may be
strategic reasons to share at a future date, I do not believe it is in your best interests to share this memo at this
time. That is not to say that you (or we) cannot share the conclusions reached with Richard, but at this time I
recommend that you preserve the confidentiality of the attached memo until such time as the positions of
potentially adverse parties are better known to us.
Once you have had an opportunity to review the memo, please give me a call if you wish to discuss it.
Best,
Deborah
Deborah Pechet Quinan, Esq. LL.M.
Shareholder
Chair. Trusts & Estates Groun
Direct: Cell:
Assistant - Jayne Mahoney:
EFTA00932847
Office: Fax:
e-mail: BIO
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Valeria Chomsky
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