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PREVIEW DOCUMENTS>>4558264
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=022207srobinson.txt
VIDEOTAPED DEPOSITION OF
13 SIMON J. ROBINSON
14 __________
15 Thursday, February 22, 2007
1 I N D E X
2 INDEX OF EXAMINATIONS
3 Page
4 EXAMINATION BY MR. TOMASIK………………… 9
5 EXAMINATION BY MR. ROSS…………………… 200
6 FURTHER EXAMINATION BY MR. TOMASIK…………. 230
7 EXAMINATION BY MR. CAMPBELL……………….. 235
8 FURTHER EXAMINATION BY MR. TOMASIK…………. 245
9
10 EXHIBITS MARKED FOR IDENTIFICATION
11
12 Exhibit No. Description Page
13 Exhibit 296 Copy of Simon Robinson's 8
personnel file, Bates HUSA-Robinson
14 0001 - HUSA-Robinson 0087
15 Exhibit 297 Fax dated 3/16/01 to Eytan Shafir 74
from Simon Robinson, Bates HUSA
16 004236
17 Exhibit 298 E-mail dated December 8, 2000 to 77
Eytan Shafir from Simon Robinson,
18 "Subject: Progress Report Boston
Operations," Bates HUSA 004233
19
Exhibit 299 E-mail dated May 16, 2001 to Simon 86
20 Robinson from Steven Bolognese,
"Subject: Checkpoint Issues," Bates
21 HUSA 004190
22 Exhibit 300 Final Corrective Action, Hassan 111
Ourazzouk, Bates HUSA 004172 -
23 HUSA 004173
24 Exhibit 301 E-mail exchange between Kevin Nolan 114
and Simon Robinson dated June 5, 2001,
25 Bates HUSA 004174 - HUSA 004175
0003
1 EXHIBITS MARKED FOR IDENTIFICATION (CONTINUED)
2
3 Exhibit No. Description Page
4 Exhibit 302 Fax dated June 5, 2001 to 119
Sherry Moran from Simon Robinson,
5 Bates HUSA 004186 - HUSA 004188
6 Exhibit 303 Document entitled, "Huntleigh USA 121
United Airlines Security Screening
7 Contact," Bates HUSA 004237
8 Exhibit 304 E-mail dated 1/24/2001 to Eytan 130
Shafir from Simon Robinson, "Subject:
9 Payrole (sic) Issues Boston," Bates
HUSA 004235
10
Exhibit 305 Letter dated April 5, 2001 to 133
11 Amanda Graham from Simon Robinson,
Bates HUSA 004234
12
Exhibit 306 FAA Test Results dated March 28, 137
13 2001, Bates HUSA 004116 - HUSA
004168
14
Exhibit 307 FAA Test Failure Information 140
15 Request dated 3/28/01 to Simon
Robinson from Jessica Neal/Joe
16 Tuero, Bates HUSA 004198 - HUSA 004201
17 Exhibit 308 FAA Test Results dated June 1, 142
2001, Bates HUSA 004210 - HUSA 004221
18
Exhibit 309 FAA Test Failure Information 144
19 Request dated 5/31/01 to Simon
Robinson from Jessica Neal/Joe Tuero,
20 Bates HUSA 004185
21 Exhibit 310 Letter dated April 16, 2001 to 148
Eytan Shafir from Simon Robinson,
22 Bates HUSA 004239
23 Exhibit 311 Copy of business cards with 150
handwritten note, "FAA people at
24 Logan that Simon dealt with on a
regular basis," Bates HUSA 004232
25
0004
1 EXHIBITS MARKED FOR IDENTIFICATION (CONTINUED)
2
3 Exhibit No. Description Page
4 Exhibit 312 Document entitled, "Civil Aviation 183
Security Passenger Information,"
5 obtained from the Internet, no Bates
numbers (5 pages)
6
Exhibit 313 Collection of FAA Test Results, 225
7 first one dated 4/17/01, Bates HUSA
004098 - HUSA 004075 (Document out
8 of Bates order)
9
PLEASE download, archive and share as PDF / Images. And ideally with summaries.
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Nabil.Nashid.Abadir.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=tim+ahern.doc
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Francis.Argenbright.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Carter.Bibbey.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Stephen.Chu.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Cora.Nilda.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Gore.Jennifer.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Fouzia.Haji.wpd
https://www.encryptomatic.com/viewer/Attachment.aspx?msgid=55c69f513fea46969a01ddcf03f4ef20&att=Ellen.Hirsch.wpd
From: Jaime Makepeace
Sent: Monday, March 05, 2007 12:38 PM
To: Timothy S. Tomasik; 'Jennifer Shafer'; 'dpepe@JOSEPHNYC.COM'; 'Tony Parsons'; 'Steve Badger'
Cc: 'Jim Warden'
Subject: RE: WTC Depositions
From: Timothy S. Tomasik
Sent: Monday, March 05, 2007 12:21 PM
To: 'Jennifer Shafer'; dpepe@JOSEPHNYC.COM; Tony Parsons; Steve Badger
Cc: Jim Warden; Jaime Makepeace
Subject: RE: WTC Depositions
I will forward to you the summaries that have been completed. I will have my legal assistant forward all the completed 9/11 summaries.
From: Jennifer Shafer [mailto:jshafer@wtglaw.com]
Sent: Monday, March 05, 2007 12:02 PM
To: dpepe@JOSEPHNYC.COM; Timothy S. Tomasik; Tony Parsons; Steve Badger
Cc: Jim Warden
Subject: WTC Depositions
We are preparing to summarize the depositions in this case, as well as to compile a comprehensive list of exhibits marked in the depositions to date. In the interests of avoiding unnecessary duplication of work, if any of you have already completed any summaries and/or compiled an index of the deposition exhibits marked to date, we would greatly appreciate a copy. To that end, please find attached the few summaries we have completed so far. I compiled the summaries using the annotation function in Live Note, hence the repetition on the headers and large margins which make the summaries appear much longer than necessary.
____
Jennifer E. Shafer, Esq.
913.491.3000 Direct 913.345.5120
Fax: 913.491.2979
____
File: 00135847.MSG 64512 bytes
Fwd: 911 Litigation–Document Subpoenas to Global Aerospaceand USAU
From: Steve Badger <SBADGER@zelle.com>
To: rac@cliffordlaw.com ; TST@cliffordlaw.com ; dpepe@josephnyc.com ; gjoseph@josephnyc.com ; sdavies@josephnyc.com ; f3g@ny.speiserkrause.com ; kpn@ny.speiserkrause.com ; Brenda Frazier ; Jennifer Shafer ; Jim Warden ; Mike Kuckelman ; Steve Badger <SBADGER@zelle.com>
CC: Jerry Gette <JGETTE@zelle.com; Tony Parsons <TPARSONS@zelle.com>
Sent time: 06 Mar, 2007 7:46:15 PM
Counsel for USAIG called me today. They are agreeable to meeting with me, but they want us to agree to drop the subpoenas for 1 year (rather than the 150 days we proposed).
I think that is too long. We issued the subpoenas last July. I dont want our hands tied that long.
I'm going to try to get authority from Allianz to to move forward with enforcement of the subpoenas. If Allianz says no, then we will consider the 1 year proposal (and likely push for agreement at some shorter period).
Steve
>>> Steve Badger 2/27/2007 6:36 PM >>>
Jon and Rob,
Thanks for both of your calls this week.
There appears to be some confusion concerning the PDPEC's proposal for a meeting with the liability insurers.
To avoid any further confusion, here is the PDPEC's proposal:
-
Myself and one other member from the PDPEC will meet with claims representatives from both Global and USAU to discuss the scope of coverage provided by their policies. Primarily, we will discuss whether the coverage for Flights 77 and 93 is responsive to our claims. Counsel for the insurers may be present. The meeting will be considered "for settlement purposes only" and therefore nothing said during the meeting can be used for any purpose in the current litigation.
-
Global and USAU will advise if they would like us to invite counsel for WTCP to attend the meeting. Otherwise, they will not be informed of the meeting.
-
The PDPEC agrees to take no further action to enforce our non-party subpoenas for 150 days after the meeting (assuming the meeting takes place in March).
Here is our objective–plain and simple. We have been told in no uncertain terms that the defendants and their liability insurers will not mediate and have no intention of ever settling the property damage claims. So it appears this case is headed to trial. Accordingly, our PDPEC must explore all insurance coverage potentially responsive to our claims. Whether the $3b in additional coverage for Flights 77 and 93 will also respond to our claims is of significant importance to the property damage plaintiffs. As part of our duties as members of the PDPEC, we must fully explore this issue. But we cannot do so without obtaining documents or other information explaining the scope of coverage. Our proposed meeting provides the insurers with an opportunity to explain why the coverage is not responsive, without the need to do so through formal document production or depositions.
Please let us hear from you soon. We need to either move forward with the meeting or proceed accordingly if our proposal is rejected.
Thanks,
Steve
______
Steven J. Badger, Esq.
Zelle, Hofmann, Voelbel, Mason & Gette, LLP
1201 Main Street, Suite 3000
Dallas, Texas 75202
phone (214) 742-3000
fax (214) 760-8994
sbadger@zelle.com
What you see here is PROOF OF LIFE. That these docs exist. This is a 4MB sample of a 10GB collection.
Yes - these docs are not sexy, this sample may be benign, but worthwhile to dig the names and context in these to prepare for the motherload.