Subject: Re: divorce
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Tue, 9 May 2000 03:59:00 -0700 (PDT)

Paul:

I received your letter yesterday -- under the circumstances, I would 
appreciate it if you would draft, execute and forward to me a motion to 
withdraw prior to your departure on Thursday for Europe.  I have not been 
able to secure other counsel as of this time, but hope to do so shortly.  
When I am able to find other counsel, I will have the motion to withdraw 
filed with the court.  I would also appreciate it if you could forward to my 
home my case file along with the family photos I gave to you.  If you have 
any concerns with these requests, please let me know immediately.  Thank you.

Linda Guinn

"paulcooley" <[email-masked]> on 05/08/2000 02:58:38 PM
Please respond to <[email-masked]>
To: "Linda R Guinn" <[email-masked]>
cc:  
Subject: Re: divorce

Linda:

Please see the attached letter.  I am also sending to you by regular mail the 
proposed changes sent to me by your husband's attorney.

Paul Cooley

---------- Original Message ----------------------------------
From: "Linda R Guinn" <[email-masked]>
Date: Mon, 8 May 2000 08:43:41 -0500

>
>
>Paul:
>
>Since I haven't heard from you I didn't know if you had received this or not.
>Below is a message I transmitted late last week.
>
>*****************************************************************************
**********************
>I'd like to subpoena Jack's apartment lease and application for Pin Oak 
Estates.
>Can you provide me with some form subpoena and I'll do whatever "leg work" 
needs
>to be done in order to minimize your time.  I know time is short for you with
>your vacation coming up.  I'm hoping Jack signed his lease (and possibly the
>application) post April 12.  However, I'm afraid he signed the application 
prior
>to the April 12 hearing date, but signed the lease post hearing date.  Is 
this
>of any significant relevance?
>
>Secondly, after we receive the lease and application, I'd like to send out 
some
>requests for production.  It doesn't seem as though we're going to be able to
>settle this, so I thought we'd be best served by getting as much information
>from them as possible.  Let me know what you think about this idea.  Below, I
>have listed a few discovery requests  ----  let me know if you think these 
are
>adequate.
>
>1.  Please produce your paycheck stubs from each full-time and part-time job 
you
>have had since January 1, 2000 until the present.
>2.  Please produce your application for apartment lease at Pin Oak Estates
>Apartments.
>3.  Please produce your lease agreement on your apartment located at Pin Oak
>Estates Apartments.
>4.  Please produce your bank statements from Chase Bank (or any other banking
>facility you have) for the months of April and May 2000.
>5.  Please produce your credit card statements for all credit cards in your
>name, both jointly with your wife and solely in your name.
>6.  Please produce all statements of the stock account in your name with the
>brokerage firm, Datek, and any other stock brokerage firm.
>7.  Please produce your 401K account statement from all such accounts both 
with
>your current employer and with your previous employers.
>8.  Please produce a copy of your current W-2 as filed with your current
>employer(s).
>
>Like I stated above, we need to get his lease agreement and application 
before
>we ask him to provide it, so he doesn't try to alter the date or anything 
else.
>
>Also, I am happy to put these discovery requests in final form or do whatever
>you think is best.  I hope you understand my need to keep costs at a minimal.
>Thanks for your advice.
>
>Linda
>
>P.S.  In light of your vacation, will there be anyone who can help me while
>you're gone?  Would you like me to ask my boss to step in as co-counsel?  I
>don't know if he's willing or not, but I can certainly ask.  After all, pride
>left me a long time ago.  Money is a factor, however, I need representation
>while you're away.  Let me know what you think.  Thanks.

 - Client, 5-8-00.doc