Geoffrey K. Calderone, Sr. - Page 8

                                        - 8 -                                         
                Following these discussions, Jacob sent a letter to                   
          respondent on June 15, 2001, in which he informed respondent that           
          he had obtained his clients’ informed consent to obviate any                
          conflict under Rule 24(g)(1) and that Hesselbacher would be                 
          entering an appearance as co-counsel to resolve any problems that           
          might arise under Rule 24(g)(3).  Jacob stated that the 1993                
          transaction might be stipulated, thereby removing any need for              
          him to testify, but, in the event he could no longer represent              
          petitioners under Rule 24(g), he would immediately withdraw his             
          appearance.  Copies of this letter were sent to Hesselbacher and            
          to petitioners.  During 2001, respondent and Jacob exchanged                
          numerous correspondence and discovery documents, all of which               
          were provided to petitioners by Jacob.                                      
                In or about June 2001, respondent’s counsel contacted their           
          National Office for guidance on how to deal with the Rule 24(g)             
          issues in these cases.  The National Office responded that Jacob            
          could continue to represent petitioners, with the understanding             
          that, in the event he was called as a witness, he would withdraw            
          and Hesselbacher would try the case.                                        
                On July 17, 2001, Hesselbacher entered his appearance as              
          co-counsel for petitioners.  Geoffrey knew that Hesselbacher was            
          representing him.  Jacob asked Hesselbacher to become familiar              
          with the cases so that, if the need arose, he could take over as            
          trial counsel.  As of July 23, 2001, respondent started                     






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011