Johann Keil and Catherine Keil - Page 15

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          decision authorized by only one petitioner, believing that                  
          petitioners could later attack it as improperly authorized by               
          only one of them while they were undergoing a divorce.                      
               At midnight of that evening, Montgomery called Tan again and           
          spoke to her for 3 hours trying to convince her that the                    
          settlements were good for petitioners.  Tan did not have any of             
          petitioners’ 1993 or 1994 financial records, and she told                   
          Montgomery that she required those records before opining on the            
          settlements.  During the morning of December 17, 2003, Montgomery           
          drove approximately 2 hours to Tan’s office to hand deliver                 
          petitioners’ files to her and to discuss the settlements.  He met           
          with Tan from approximately 11 a.m. to 4 p.m.  Tan informed                 
          Montgomery at the end of that meeting that she still was unable             
          to opine on the settlements because she was uncomfortable with              
          the accuracy of certain numbers used by his accountant in                   
          computing amounts reflected in the settlements.  Montgomery told            
          Tan not to worry because his insurance carrier would cover any              
          expense resulting from an inaccurate computation by him or his              
          accountant.  Tan continued to decline to opine at that time.                
               Also on December 17, 2003, Montgomery spoke to Mr. Keil for            
          approximately 10 minutes.  During that call, Montgomery again               
          tried to convince Mr. Keil to approve the settlements and stated            
          that any mistake in them would be remedied by his law firm.  Mr.            
          Keil declined to accept the settlements.  Montgomery informed Mr.           






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