From: To: Cc: Bcc: Subject: Date: Attachments: Michael Lampe James Murphy Todd Wynkoop (Todd.Wynkoop@mccormickbarstow.com); "Jason Howard"; Michael Smith Chuck Hansen FW: Tulare v. Greene Wednesday, March 25, 2020 3:30:00 PM image001.png image002.png image003.png image004.png image005.png image006.png 3684350.pdf Jim:   Reference is made to your correspondence of today’s date.   You assert that, “It is obvious that the District’s action in publishing the proposed State Bar Complaint is a mere litigation tactic designed to pressure the firm and Mr. Greene in the ongoing lawsuit …”   As I previously advised you in writing, the proposed State Bar complaint is procedurally unrelated to the civil litigation now pending.  If the Board adopts Resolution 886, my office does not intend use, and indeed could not use, the filing of a State Bar complaint to its advantage in the pending civil litigation.  Any issue you may have with a Public Agency conducting its business in public is really beside the point.   You further note that, “Your actions certainly raise issues for the District’s General Counsel under RPC Rule 3.10.”    Please know that the proposed complaint was drafted by me in its entirety.  Any issue that you think may arise under Rule 3.10 falls on my shoulders alone, not District General Counsel.  Feel free to file your own complaint against me with the State Bar if you deem it appropriate to do so.  I will not hold it against you, and am confident that nothing will come of it.   Finally, and most importantly, you make the claim that the draft complaint is “factually inaccurate.”   Please feel free to advise as to those facts that you believe are inaccurate and I will make sure that your concerns are put in front of the Board for its consideration.  In the alternative, you are free to address the Board directly.  Instructions for addressing the Board electronically or telephonically can be accessed on the Board’s website.   I am completely comfortable with the facts recited in the proposed complaint.  As you know, those facts are supported by the sworn testimony of Dennis Mederos, Kevin Northcraft, Teresa Jacques, Benny Benzeevi, Bruce Greene, Linda Wilbourn, and Los Angeles Attorney Cary Davidson, as well as written communications from your office.   Thank you for you correspondence.     www.lampe-law.com   Michael J. Lampe Law Offices of Michael J. Lampe 108 West Center Avenue Visalia, California 93291 Telephone: 559.738.5975 Facsimile: 559.738.5644 mps@lampe-law.com   Note: This message is intended for the individual or entity to whom it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient of this message you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited. If you have received this message in error, please notify us immediately by replying to this message, "Received in Error," in the subject heading and then delete the message from your system. Thank you.   From: James Murphy Sent: Wednesday, March 25, 2020 2:18 PM To: Michael Lampe Cc: Lucchesi, Thomas ; Harlan Watkins ; David C. Scheper Subject: Tulare v. Greene   Mike, hope you remain well. See attached letter. Jim   Sincerely, James A. Murphy James A. Murphy Shareholder     580 California St., Suite 1100 San Francisco, CA 94104-1032 Office: Fax: 415.788.1900 x2801 415.393.8087 website bio vCard map email   Voted "Best Legal Malpractice Specialty" by readers of The Recorder for the tenth consecutive year in 2019!   See our published articles, presentations, events & other news   Named as a Northern California Super Lawyer             CONFIDENTIALITY - This e-mail message and any attachments thereto are for the sole use of the intended recipient(s) and contains a private, confidential communication protected by the attorney client privilege and the attorney work product doctrine. Any unauthorized review, use, disclosure or distribution of this e-mail is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Thank you.       PLEASE NOTE:  As of March 2, 2020, Murphy, Pearson, Bradley & Feeney’s new San Francisco address will be: 580 California Street, Suite 1100 San Francisco, CA  94104-1032 Phone and fax numbers will remain unchanged.