2-I Example of Gooch Privileged Emails, line 3612


2-I)  EXAMPLE OF GOOCH EMAILS



On October 29, 2019 at 4:58 PM Williams sent an email to Dulberg stating:

Dear Paul,
Attached please find revised supplemental interrogatories.
I am a bit concerned that we are making Attorney Gooch a witness in the case and that in doing so may waive attorney client privilege
as to him by disclosing him as the “expert witness” identified in your complaint. That being said, I did my best to state that you
discovered that something was wrong only after receiving the award in Dec. 2018 and then consulting with Attorney who agreed to
take the case.
Please review.
Best Regards,
Julia Williams

2023-03-04_FINISHED Collection of Emails-Clinton firm/2019-10-29_1658 PM_RECV_Discovery and status update_ATTACHMENTS.pdf






On Oct 21, 2019, at 1:40 PM Williams sent an email to Dulberg stating: 

Please review and respond by close of business on Thursday, October 24, 2019.
Please note that I believe that you first realized the legal malpractice case against Mr. Mast and the
Popovich firm was viable when you received Dr. Bobby Langford’s report. The report is dated February
2016, but in the Complaint we allege that you came to learn of the legal malpractice in December 2016.
Please verify the date that you learned of the legal malpractice case. Was it in fact with Dr. Langford’s
report in February 2016? If not, please explain. If so, we can amend the complaint to make that
consistent.

2019-10-29_1658 PM_RECV_Discovery and status update_ATTACHMENTS.pdf