- Forum Clout
- 78,241
From: Brinton Resto <[email protected]>
Date: Tuesday, November 9, 2021
CONFIDENTIAL SETTLEMENT COMMUNICATION
Hi Ruben,
My rejects your client’s material changes to the original offer of settlement that omits a mutual release and your client foregoing seeking fees related to the Google subpoena. My client also rejects the vague request for additional compensation of his attorneys’ fees unrelated to the Court filings.
I have attached an agreement outlining the core terms of the agreement with a mutual release in place to limit further litigation and attorneys’ fees related to <onaforums.net>. As to anonymity and the agreement, your client may simply execute a John Doe signature in the same fashion as he did with the court filings and your firm may retain an original declaration alongside it with his full legal name for attorneys’ eyes only, in-camera inspection, if it ever came down to that. Any changes you may propose cn (sic)
There will be no lump-sum payment of the fee award to your client via settlement in the absence of a mutual release and your client foregoing any attempt to collect fees on the Google subpoena. With that in mind, let us know if your client wants the fee award wired or not.
Sincerely,
Sic added by me. nice incomplete draft, stupid.
If Doe breaches this Agreement by seeking relief based on any conduct released pursuant to
paragraph 4, including a request for fees incurred in the Google Action or taking any action against
Tomlinson or his attorneys based on the conduct of either Tomlinson his agents, attorneys,
successors and assigns that predates this agreement,
hmm........