Document N2NZJoOdO9nrBvwjq7Dr0kNoV

TO: FROM: RE: DATE: MEMORANDUM J. RANDALL JONES CHUCK McC CONVERSATION WITH BILL SNYDER May 12, 1992 Bill Snyder called- He had spoken with Guy Marvin, in-house counsel for Independent Life Insurance Co., about the Sea Island, GA meeting at which Independent and GE settled the case in which Independent sought damages for changing out PCB transformers in a commercial building Independent owned. Marvin said that under the terms of the settlement agreement, he absolutely could not discuss any aspect of the case. Bill then asked him directly whether Manny Neil was present at Sea Island. Marvin replied that Neil had been present at nearly all of the court hearings, but that he (Marvin) couldn't comment on whether Neil was or wasn't present at Sea Island. Snyder also asked Marvin whether the settlement included any amount to cover an anticipated award of punitive damages. Marvin again replied that he simply couldn't comment. If Neil had not been at Sea Island and there had been no increment of punitive damages recognized in the settlement, the answers would have been easy. An honest man - one who could not disclose the truth and would not tell a lie - could only have answered as Marvin did. I guess what we may conjecture from this is that Neil, having bet the ranch and lost at the 9th Circuit, may be pragmatic enough to really want to settle the case - just as, after reading the Memorandum May 12, 1992 Page 2 /k handwriting on the wall, he settled the Independent Life case at Sea Island. Randall, I will be out of the office Wednesday, Thursday and Friday. I will instruct Carol to transfer to you any call I receive from defendants9 counsel. I have of course made no arrangements yet for any meeting place. chm \nevpow e r \s e a i s l n d .nvno