B: FAILURE TO COMMUNICATE WITH COUNSEL.
During Mr. Colvin's December 27 and 28, 2001 meeting with plaintiffs in Vancouver British Columbia he informed Mr. Price that he needed copies of the defamatory statements posted on the raging Bull site. Mr. Colvin further informed Mr. Price that he anticipated Defendant ****** would be filing a Motion to Dismiss based on lack of personal jurisdiction and advised that he would need copies of Mr. ******'s defamatory Internet postings. Mr. Price stated that he would bring them with him when he met with Mr. Colvin in Reno Nevada on February 8th. Mr. Price inadvertently or otherwise did not do so.
During the February 8, 2002 meeting between Messers. Colvin and Price in Reno, Nevada, it was again discussed that Mr. Colvin needed copies of Mr. ******'* defamatory postings. On or about February 18, 2002, Mr. Colvin again asked that the ******'* postings be sent to him. On or about the same day, Mr. Colvin telephoned Larry Regis about the fact that his bill had not been paid, that Les Price was not responding to his telephone calls, and that Mr. Colvin needed the ****** documentation in order to oppose Mr. ******'* motion to dismiss. On February 25, 2002, Mr. Colvin spoke with Mr. price about his bill and again requested that he be provided with copies of Mr. ******'* postings. On February 28, and March 1, 2002, Mr. Colvin telephoned Mr. Price and was informed that Mr. Price was unavailable. Mr. Colvin left a message stressing how important it was for him to recieve copies of Defendant ******'* defamatory postings. Mr. Price did not return Mr. Colvin's telephone calls. |
