From: Valeria Chomsky To: "jeffrey E." <[email protected]> Cc: Noam Chomsky Subject: Fwd: Legal Memo Regarding Distribution Standards Date: Wed, 06 Dec 2017 22:20:26 +0000 Attachments: Chomsky _Memo_re_Carol_Chomsky_Marital_Trustsianalysis_of discretionary_distribution_standa rd)_-_2017_(00667474xA4627).pdf Inline-Images: image001.gif Forwarded message From: Deborah Pechet Quinan Date: Wed, Dec 6, 2017 at 10:03 AM Subject: Legal Memo Regarding Distribution Standards To: Noam Chomsky , Valeria Chomsky Dear Noam and Valeria, Attached is the memo we have prepared addressing the above-referenced issue. Please note that as there may be litigation in the future on this issue, we have marked the memo as "Privileged and Confidential Attorney Client Communication and Work Product". Generally, attorney-client communications are protected from discovery in judicial proceedings. The privilege is lost, however, upon disclosure or dissemination to a third party. This means that if you share this memo with Richard Kahn or with anyone else who is not your attorney, the memo will be discoverable and adverse parties will have access to our arguments and analysis. While there may be strategic reasons to share at a future date, I do not believe it is in your best interests to share this memo at this time. That is not to say that you (or we) cannot share the conclusions reached with Richard, but at this time I recommend that you preserve the confidentiality of the attached memo until such time as the positions of potentially adverse parties are better known to us. Once you have had an opportunity to review the memo, please give me a call if you wish to discuss it. Best, Deborah Deborah Pechet Quinan, Esq. LL.M. Shareholder Chair. Trusts & Estates Groun Direct: Cell: Assistant - Jayne Mahoney: EFTA00932847