Ce aan awn 10 il 12 3 14 15 16 7 18 19 20 2 23 2% 25 26 The Honorable Steven Gonzalez Noted for Hearing: May 30, 2008 at 10:00am Oral argument requested Defendants’ Opposition to Plaintiff's Motion for Partial Summary Judgment ‘Against the George Defendants Re Breach of the Standard of Care SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY CHRIS CORNELL, ) ) Plaintiff, ) No. 06-2-24639-0SEA ) ve ) DECLARATION OF JANET A. } GEORGE IN SUPPORT OF GEORGE VOLDAL, WARTELL & CO., P.S.,a ) DEFENDANTS? OPPOSITION TO ‘Washington Professional Service Corporation; ) PLAINTIF’S MOTION FOR LEE E. JOHNSON; JANET A. GEORGE; and) PARTIAL SUMMARY JUDGMENT. JANET A. GEORGE INC. P.S., a Washington) RE BREACH OF THE STANDARD Professional Service Corporation, ) OF CARE ) ) Defendants. SaESSSSSESESEISESSIESSEISESSIS=ESSOsSHSoCecssSaw Janet A, George declares as follows: 1, Tam one of the named Defendants in the above captioned case. [have personal knowledge of the facts set forth herein. 2. filed a petition for divorce on behalf of Chris Corel! (“Cornett”) in October 0f 2003, King County Superior Court Case No, 03-3-10502-7SEA. Silver was represented by ‘Tom Hamerlinck (“Hamerlinck”). 3. By November 2003, Cornell told me that Silver had said she wanted a settlement for more than half the property. A true and correct copy of an email Ireccived DECLARATION OF JANET A. GEORGE - | ae on ue ORIGINAL “===Cer aun 10 ist 12 13 14 15 16 7 18 19 20 21 2 23 24 25 26 from Chris Comell dated Novernber 11, 2003 stating the same is attached as Exhibit 3 to the Declaration of Ralph E. Cromwell, I. 4, In November 2003, I wrote to Comell regarding the need for Rick Schneider, a California entertainment attorney with whom I had previously worked, to assist with the intellectual property. A true and correct copy of my email to Comell referring to Rick Schneider is attached as Exhibit 3 to the Declaration of Ralph E. Cromwell, J 5. Onorabout January 11, 2004, I wrote an email to Chris Comell outlining the divorce process and explained to him that it would take at least two to four months to obtain a 00d parenting evaluator and six to eight weeks to complete. A true and correct copy of an cemail I sent to Cornell dated January 11, 2004 stating the same is attached as E Declaration of Ralph E. Cromwell, Jr. 6 On January 20, 2004, I spoke, via telephone, with Chris Comell regarding the it 4 to the divorce. During the call, Cornell told me that, to induce Silver to agree to a quick divorce, he has already offered to Silver the houses in West Seattle and Ojai and a 50/50 split of everything else, A true and correct copy of the notes from my telephone conversation with Comell dated January 20, 2004 are attached as Exhibit 5 to the Declaration of Ralph E. Cromwell, Jr. That same day I called Hamerlinck and conveyed Cornell's offer. I then confirmed Comell’s offer, in writing, in a letter to Hamerlinck dated January 21, 2004, a true and correct copy of which is attached hereto as Exhibit 1. 7. On January 22, 2004, I emailed Comell to tell Comell about Hamerlinck’s response, that Silver wes “really blown away, fragile, not handling it well” and that Hamerlinck was unsure “if'I can push her.” A true and correct copy of my email to Cornell dated January 22, 2004 is attached as Exhibit 6 to the Declaration of Ralph E. Cromwell, Jr 8. informed Comell that Silver had not agreed to promptly meet with a parenting mediator on January 26, 2004, in an email. On January 27, 2004, in response, I received an email from Cornell, stating that Hamerlinck “needs to know that I am not DECLARATION OF JANET A. GEORGE -2 Bynves & Kure Sears. Wasitmoren 98104 ‘06122-2000Ce wan ew 10 ul 12 13 14 15 16 7 18 19 20 21 2 24 25 26 bullshitting about my generous offer being reversed if this docs not move now.” A true and correct copy of my email to Comell dated January 26, 2004 and Comell’s response email dated January 27, 2004 are attached as Exhibit 7 to the Declaration of Ralph E. Cromwell, Jr. 9. set to work to prepare for a mediation by the March | deadline Comell had set for his offer. In late January 2004, my office contacted Steve Winters, on Comnell’s behalf, to essist with intellectual property issues, 10, On February 17, 2004, I emailed Comell that “We/they arc moving forward, ‘but not as fast as you would like.” A true and correct copy of my email to Comell dated February 17, 2004 is attached as Exhibit 8 to the Declaration of Ralph E. Cromwell, Jr 11. Again, on February 17, 2004, I emailed Comelt and told him that it would be logistically difficult to meet his March 1 deadline and I asked him to consider a brief ‘extension. A true and correct copy of my email to Cornell dated February 17, 2004 is attached as Exhibit 9 to the Declaration of Ralph E, Cromwell, Jr. I received no response to my email to Cornell requesting an extension of his Mareh 1, 2004 deadline, 12, On February 19, 2004, I again emailed Comell stating, in part, that wrapping the divorce up by March | was “almost impossible” and that “in this rush, I am concerned that issues are not clear.” A true and correct copy of my email to Comell dated February 19, 2004 is attached as Exhibit 11 to the Declaration of Ralph E, Cromwell, Jr. Several hours later on February 19, 2004, Comell emailed me that “It can only get worse for them, Idon’t buy that March first is impossible. If they want it done it will be done.” A true and correct copy of Comell’s email to me dated February 19, 2004 is attached as Exhibit 12 to the Declaration of Ralph E. Cromwell, Jr 13, With less than two weeks away from Comell’s March 1" deadline, i continued to ty setting up a mediation for Cornell and Silver to identify and resolve issues. Comell was in Paris and Silver was difficult to reach. A true and correct copy of my email dated February Byrnes & KELLER us erm Fioor SEATTLE. WASHINGTON 98104 ‘2001 922-2000 DECLARATION OF JANET A. GEORGE -3