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58.

Nor is a screen implemented effectively if it is not established until

months after the disqualified attorneyjoins the law firm.

59.

To Mr. Casey’s knowledge, no screening instructions were communicated

orally to anyone .at the Firm (other than himself) and the only written screening

instructions disseminated to him or anyone else in the Firm were set forth in a

memorandun sent as an e-mail attachment in December 2009, more than two months

after Mr. Caseyjoined the Firm.

60. ?d Dissemination of a written memorandum more than two months after Mr.

a Caseyjoined the Firm was untimely and renders the screen ineffective.

61.

Although Petitioners’ counsel requested a copy of the memorandurn at the

deposition o f Mr. C k e y and afterwards, K&K has not provided a copy. Likewisc,

to the U.S. Attorney’s Office pursuant to Rule 1.1l(b)(l)(iv), K&K has not provided a

There Exists A Serious Appearance Of Impropriety

62.

On information and belief, the U.S. Attorney’s criminal Investigation into

Lehman’s s’aleof ARS was instigated by a referral from K&K to Mr. Casey. The referral

and Investigation focused, among others, on the circmstances surrounding the ARS

purchased by Essex -- the same transactions that are the subject of Respondents’ claims

in the Arbitration.

63.

After Mr. Casey commenced and pursued the Investigation at K&K’s

behest and gained confidential information using the subpoha power and investigative

resources of the federal government, he was hired by the Firm as a partner.

15

Supreme Court Records OnLine Library - page 18 of 22

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