| SUMMARY SERVICES |
|
TASKS
DONE - RE: TO DO LIST DATED
10/24/01
|
10/24/01
Eve talked to client briefly regarding the immigration information needed.
Faxed a letter with the questions to client.
10/25/01
Client called AM and he had some immigration papers, and he didn’t get fax.
Eve scheduled client’s appt. with Paul for 2/26/01, 2:00PM.
I faxed the letter with the questions to client again.
10/23/01
Eve called the AG’s office and left a message for Lisa Ott. She returned the call and informed her that the AG’s office will not be filing their answer to the Habeas until the Court made a decision regarding their motion to dismiss, and that the date for a hearing on their motion had been vacated.
10/24/01
Paul drafted a status conference statement, mailed by Sonja10/24/01, informing the Court that the AG’s office had refused to answer our habeas, conduct directly against the Court order to answer. The AG filed a motion to reconsider the Court’s order.
10/25/01
It will be timely filed, but Sonja will call and confirm when it’s filed.
10/23/01
Eve phoned Jane and John Doe and found that the cell phone contact number for Jane was wrong. John Doe returned Eve’s call and told her that he would call Jane and have her call Eve.
Jane called and discussed getting the medical records and presenting a strong position regarding her husband John Doe’s diabetes having worsened by the stress of the incarceration. During the five years prior to incarceration, his condition had stabilized and his prescription was unchanged. Recently client’s medication had to be tripled because the prison lab results showed client’s sugar levels were up to 349; normal is 90-110.
Jane mentioned Dr. Smith in San Francisco, and Dr. Brown of Kaiser Hospital in Oakland. She will get the medical records and doctor’s recommendation and forward them to our office.
10/24/01
Jane Doe called to inform Eve that she had faxed a medical release to Dr. Smith’s office.
The possibility of doing an appeal for the client was discussed, whether client could afford to pay Bob the amount of $10,000, to represent him, payment plan to be paid in two payments of $5,000 each, and the option of First District Appellate Project doing the appeal. Sally stated that client couldn’t afford to pay for the appeal and assured her that Bob had offered to do client’s appeal for free in August because he could use it as a tax write-off; so, it was unnecessary to send the case to the First District Appellate Project. Eve drafted a status letter to G re: the First District Appellate Project. DONE
11/24/01
A draft of the status letter, re: denial of the writ and the cost of representation in the appeal by this law office; was placed on Jerry’s desk for his approval. He decided on charging $5,000 for the appeal.
10/25/01
The letter was completed and placed in Jerry’s box for his approval.
10/23/01
Eve discussed with Paul the need to hire Brian Olivier for a follow-up investigation. Bob wants to decide 10/26/01 whether to hire him or not.
1/24/01
Habeas to strike the priors was done and placed in Bob’s office for his OK.
10/24/01
Marivel had some different goals to add, which came from her calendar:
RE: 72601, need transcript, add exhibits, plea bargain and expungement of DUI.
Neither she nor Eve can figure out the deadlines? Ask Paul about the schedule?
10/24/01
Eve called the client’s mom and talked to his sister-in-law, Nicole. She gave her the client’s current address.
10/25/01
Eve will draft a letter
to the client requesting that he call to schedule a phone appointment with
Paul. DONE
10/25/01
Sonja is attempting to find the dismissal documents. Eve will draft a cover letter and she will mail them.
10/26/01
Status letter are to be pre-approved by Bob.
10/23/01
Re: Guardianship; Mom was served.
10/24/01
Paul drafted the temporary guardianship doc’s.
10/25/01
The temporary guardianship doc’s will be filed.
The hearing was continued to 12/11/01.
10/24/01
Jerry and Paul briefly discussed the Hobbs motion. Paul said 1538.5 and a Hobbs motion are the same thing.
10/25/01
Paul is drafting the Hobbs motion.
12/23/01-12/06/01
The medical reports will be mailed after Bob talks to the client.
10/24/01
Paul sent letters to Attny. for Def., re: deposition and settlement.
10/25/01
Paul, the Answers to ROGS, Admissions, and production of
documents are due.
12/23/01
Returned phone call of AB, client’s brother’s wife, and left a message to call and schedule an appointment. The draft of the Potential Witness List is done.
12/24/01
Eve called AB, and left a message with the young man, who answered the phone, to have her call and schedule an appointment.
12/25/01
Eve plan to phone AB again. I will proof and edit the Potential Witness List.
L, C
12/23/01-12/26/01
Paul did work on the motion and petition.
10/23/01
The Motion For Certificate of Appealability is still pending.
10/24/01
Awaiting Bob’s approval to send the info to Brian Oliver.
10/23/01
Annie phoned Dr. Berg. He is on vacation until 10/25/01 and will call back when he returns. Client will call again 10/26/01.
10/23/01-10/26/01
Eve is to call his attorney to get a status check or an explanation of his last phone message re: status.
10/23/01
Eve called the J’s family and told them that the appeal is on.
10/25/01
Eve will write a status letter to client.
10/26/01
Eve wrote the status letter.
10/24/01
Paul took DMC’s name off of documents. DMC will file them by 10/25/01
10/24/01
Eve called R D re: an appeal and the return of the motorcycle. R said that also the motorcycle has already been returned, client cannot afford to hire Bob to represent him for appeal and will seek a court-appointed attorney. R wants to pick up the client’s file on 10/26/01. Eve will call her back regarding this on 10/25/01.
10/24/01
DMC wants to see the revised draft of the global settlement Agreement.
10/25/01
Eve will make sure DMC gets the revised draft from Paul.
10/24/01
Final report is due
Sentencing memo is due
We received the pre-sentence report. It’s on for sentencing 11/26/01.
10/24/01
Marivel will write a letter to the son re: paying for his father’s appeal.
10/25/01
The trial begins 12/01/01. What are the pre-trial dates?
10/24/01
The POA’s re: guardianship were done.