FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / witness-prep-memo-navarrete.docx
witness-prep-memo-navarrete.docx · 1045-00007

Parties

Harkness LLP
Whitfield Keane LLP
Stein LLP

Dates

January 12, 2024
January 18, 2024
November 22, 2023
February 28, 2023
May 10, 2023
August 9, 2023
December 31, 2022
September 18, 2023
October 12, 2023
January 1, 2020

Amounts

$47.2
$5.1
$143.5
$4.1
$180.8
$37.3
$612
$30.6
$6.7
$236.4

Obligations

Should her interests and the entity's interests diverge at any point — including during the preparation sessions or during the testimony itself — we must be prepared to address that divergence promptly, including by suspending the preparation or the testimony to allow her to consult with independent counsel
However, "I don't recall" must be truthful — if she does recall, she must say so
She must be truthful in every answer, even when the truth is uncomfortable or inconvenient for BRB's position
There is no single "correct" ACL; rather, there is a range of reasonable estimates, and management must exercise judgment in selecting an estimate within that range
Navarrete must not reference the Brindoval engagement, Dr
Navarrete must be carefully instructed on the boundaries of privilege during testimony