From: Scott Link To: jeffrey E. <[email protected]> Subject: Re: Project VI- Proposal For Settlement Date: Thu, 19 Oct 2017 20:52:51 +0000 Jeffrey my recommendation is to allocate $10,000. Based on my conversation with Gunster there's an advantage even if it's slight to an allocation. The optics of 10,000 are OK. It's a small number in the event it ends up in the press, but large enough that it should meet the good faith standard. Scott Sent from my iPhone On Oct 19, 2017, at 4:49 PM, jeffrey E. <[email protected]> wrote: scott. it is a matter of judgement that should rely on local experience. not sure how punis work in florida. its an interesting question . my guess is to offer something. , On Thu, Oct 19, 2017 at 9:42 PM, Scott Link wrote: Jeffrey -below in this string is an analysis from the Gunster proposal for settlement guru. In essence the question is should we allocate some amount to their claim for punitive damages. If we allocate some amount the proposal has a better chance of being upheld after we win the trial. Optically, I never like to give credence to a claim for punitive damages so I typically allocate zero dollars to the punitive damage claim. Gunster has proposed $100,000 allocation. In a follow up call they have concluded that $1000 to punitive damages is better than an allocation of zero. $10,000 is better than $1000. Obviously the higher the amount the better argument we have that the proposal was made in good faith. Please let me know if he would like to allocate zero, $1000, $10,000 or some other amount to punitive damages. Also let me know if I have the authority once that decision is made to serve the proposal in the aggregate amount of $ 600,000. Scott Sent from my iPhone Begin forwarded message: From: "Atkinson, David" Date: October 18, 2017 at 7:33:29 PM EDT To: '' I< > I Subject: Fwd: Project VI- Proposal For Settlement Sent from my iPad. Please excuse tone and typos Begin forwarded message: From: