Brian C.

Shrive

From: Don McTigue <dmctigue@electionlawgroup.com>

Sent: Tuesday, October 30, 2018 7:43 AM
To: Christopher P. Finney
Cc: Brian C. Shrive; pdemarco@msdlegal.com; Brandy E. Fitch; Emma Brodzki; Peter J.
O'Shea; Brian (Perkins Coie); Derek Clinger
Subject: Re: Thursday hearing

Chris,

Your statement that no one seems to know anything relevant is a bit disingenuous given that you & Brian have
taken only two discovery depositions when Brian's original 10/2 email about scheduling depositions said that
he planned to take six depositions, including those of Sarah Topy, Drenko Pureval, Joseph Levy and Mark
Byron, which were not taken. Also you sat through Mr. Pureval's deposition and heard him repeatedly answer
Brian's questions about whom he thought would know the answer to Brian's questions and those answers
included there of these individuals.

Don

___________________________
Donald J. McTigue
Attorney at Law
McTIGUE & COLOMBO LLC
545 E. Town Street
Columbus, Ohio 43215
Tel: 614-263-7000
Cell: 614-832-5984
Fax: 614-263-7078
dmctigue@electionlawgroup.com

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Act. If you have received this email in error, please immediately notify us by telephone, and delete the original.

On Mon, Oct 29, 2018 at 4:00 PM, Christopher P. Finney <Chris@finneylawfirm.com> wrote:

We are not sure of the order of our witnesses, no. And Aftab would not be first.

If you want to cooperate as to producing witnesses, tell us who has all the secret information, we are glad to
cooperate. However, since no one seems to (or claims to) know anything relevant it may take some time to wade thru
things.

1
Christopher P. Finney, (513) 943-6655 (o), (513) 720-2996 (c)

From: Don McTigue <dmctigue@electionlawgroup.com>

Sent: Monday, October 29, 2018 3:58 PM
To: Brian C. Shrive <Brian@finneylawfirm.com>
Cc: pdemarco@msdlegal.com; Christopher P. Finney <Chris@finneylawfirm.com>; Brandy E. Fitch
<Brandy@finneylawfirm.com>; Emma Brodzki <emma@finneylawfirm.com>; Peter J. O'Shea
<poshea@katzteller.com>; Brian (Perkins Coie) <BSvoboda@perkinscoie.com>; Derek Clinger
<dclinger@electionlawgroup.com>
Subject: Re: Thursday hearing

Brian,

Are you agreeable to calling him as your first witness so that he can then be released?

Don

___________________________
Donald J. McTigue
Attorney at Law
McTIGUE & COLOMBO LLC
545 E. Town Street
Columbus, Ohio 43215
Tel: 614-263-7000
Cell: 614-832-5984
Fax: 614-263-7078
dmctigue@electionlawgroup.com

Unless otherwise evident from the nature of the communication, the information contained in this email message is
attorney-client privileged and/or confidential information intended for the use of the individual or entity to
whom/which it is addressed. If the reader of this message is not the intended recipient, or the employee or agent
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On Mon, Oct 29, 2018 at 3:55 PM, Brian C. Shrive <Brian@finneylawfirm.com> wrote:

2
We intend to call Mr. Pureval as a witness at the hearing on November 1, and we are not willing to submit his
deposition transcript in lieu of live testimony.

Thank you,

Brian C. Shrive, Esq.

FINNEY LAW FIRM, LLC

4270 Ivy Pointe Boulevard, Suite 225

Cincinnati, Ohio 45245

513.943.6656 (o)

513.482.9321 (c)

Brian@FinneyLawFirm.com

*******************PRIVATE AND CONFIDENTIAL********************

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received this electronic transmission in error, please notify by telephone (513-943-6656), collect or by electronic mail Brian@FinneyLawFirm
destroy the original transmission.

Thank you for your assistance.

From: Don McTigue <dmctigue@electionlawgroup.com>

Sent: Monday, October 29, 2018 3:28 PM
To: Brian C. Shrive <Brian@finneylawfirm.com>
Cc: Peter J. O'Shea <poshea@katzteller.com>; Brian (Perkins Coie) <BSvoboda@perkinscoie.com>; Derek Clinger
3
<dclinger@electionlawgroup.com>
Subject: Thursday hearing

Brian,

After taking Mr. Pureval's deposition are you still planning on calling him as a witness at the hearing now
that you are aware of what information he has and does not have? We would be willing to agree to submit
his deposition transcript in lieu of re-testifying. We would effectively be giving up our opportunity to ask him
questions.

Don

___________________________
Donald J. McTigue
Attorney at Law
McTIGUE & COLOMBO LLC
545 E. Town Street
Columbus, Ohio 43215
Tel: 614-263-7000
Cell: 614-832-5984
Fax: 614-263-7078
dmctigue@electionlawgroup.com

Unless otherwise evident from the nature of the communication, the information contained in this email message is
attorney-client privileged and/or confidential information intended for the use of the individual or entity to
whom/which it is addressed. If the reader of this message is not the intended recipient, or the employee or agent
responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution, or
copying of this communication is strictly prohibited. See 18 U.S.C. §§ 2510-2521, the Electronic Communications
Privacy Act. If you have received this email in error, please immediately notify us by telephone, and delete the original.