Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-01551-JJF Document 379-9 Filed 10/05/2007 Page1 of 2
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Case 1:04-cv-01551-JJF Document 379-9 Filed 10/05/2007 Page 2 of 2
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`Ga ne, Roderick ‘ ° . 3 { _ __ _ :{;
%03:i‘»T$?i‘ From: Gagnm Rcdarlck . · - · -
Sent: Thursday, October 03, 2002 12:36 PM
T0: Yau (E~maH) _ . .
Subject: ‘ Mjsceilanecus Matters .
' `Daar Andrew, · - i V l
As TGQQBSYBG; I slept cm the various things wé have diécussad and have the foiiowing thoughts: _ *
4. Regarding your request far me to Eapapsr tha mms in March from Bob Bash and the Trusts in which he andél are _
‘ Trustees as a loan to you personally as 0pp¤sad=t¤»¤ loan to Student Finance Gurpcratton, Iwill not do lt because {a} it Is
wrong, never being the dsa! or the business armngemenf. and (b) can not dc It since it has aiready been papsrcd and sent ‘
in SFC on JuEy10. 2002 for delivery to its accountants, was paper:-zd with Wmis Fargo In March and the money flnwwanf _ ·
to SFC In March, who was to be the collateral agent for the promised iceans Hxatwere never forthcoming. For your . ‘
information, in my opinion it would be a criminal act tc change the documents slnca It would ,p¤tanHa1IyaId,and abef a · ;_
fraud on creditors and tim IRS. We have worked together for many years, but I have never and vvili neva: counsel orparmit j:
. you *10 take an iifegat ur unlawful acticwwlih my assistance or cunsnt. · _ · . ' .
2. P@P¤ar Hamilton is not In position to represent the two entities going forward -bec:ause of Perry' sv involvement with them. jj E
{witnessed Hrst hand his. in the hast tight, materlai misstatemants of fac!. Moreover, the aniirc forbearance account ‘ _
agreement was done against my advice and with cut our consent, which Is. why it was prepared by Fnx Rothschild; In fact, _
· Pony sent everything. he could to other law firms,. so Ii do not think ihat it wcuid work. · . E
3. I want to begin the process of tile changcin control at PEG_f¤r several reasons. but mnst !m'p¤ntantiy iwant the flilngs ‘
with thc state and federal dapanjimgnts uf education to represent the aciual holdings. I have raised this cqnslstamly in the .
past and {think this is a prcpitious time tg} move fcsward. Moreover, we nesclm do sum refiactvariuus changes iruha ’ _
trust As an asidzai it is also imporiantic evidence our consented to exewtirm against the stuck of Paemiar Education . ‘ E
Group @.5*. Inc, 0ns‘Summlt Plane Partners GP. inc. and BHP GP., inc:. can Juno 18, 2092 in the evantthat Wllmlngtdn - ; =
Trust attempts to overturn the same. in fact, Bob has asked that we sntasiudgment to assert our ciaims agairist your _
other assets In an effort to assistycu In thwarting WTC. I have been negligent In passing iijzls along to ycu. . g g
Ewcmid be fxappyin discuss any nf the points raised with you at your ccnvenlence. ` · "
' W. Roderick Gagné · . _ _ ‘ .
Pepper Hamilton LLP · V 4 __ `
3000 No Logan Squaw ' _ j‘
. 1S”*.& Am]: Sixceps _ _ _ - _
Fhilzdclphia, ?A 19103 ‘ ' · gi
I>imct1Dia1:{225) 9814695 ` - _ .
Facsimiicz (215) 981—4'75U‘ .
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