From: Darrin L. Clayton, CLAYTON LAW OFFICE Sent: Thursday,
August 27, 2015 9:01 AM To: Larry Segal Subject: re: Friedman

Without Prejudice

I acknowledge receipt of your correspondence dated July 16, 2015.

A few points.

First, this is not a complicated situation. The parties have 10
children. As a result, they have no money. They have very limited
incomes. They have basically one asset : the house. The parties
are fully aware of what each other have e.g. four bank accounts
that they all have access to. Devorah was hoping to complete
this process as quickly as possible with minimal fees to move
along. After all, any professional fees comes out of their meagre
savings or the house. There is no income to pay for anything.

Second, both parties have the ability to work. Neither party is
earning any significant amount of money. Devorah's income is
nowhere near $60,000.00 per annum. Barry is well aware of the
income. They will both be fortunate to have enough money to eke
out a living going forward. Neither party has the ability to
pay spousal support to the other. Your client is a smart and
resourceful man who earned a very significant income at one
point. He has at present several sources of income. He has the
ability to generate as much revenue as does Devorah -- more in
fact.

Third, the above being said, if Barry wants to pay lawyers to
complete financial statements and to produce disclosure that he
already knows the answers to then he has that right. We will
proceed with the standard disclosure as I assume that Barry will.

Fourth, the inescapable conclusion is that the house has to be
sold. The current living arrangements are not good. Devorah
proposes to list the house for sale immediately with Theresa
Quann Bakker, Sean McCann or Paul Rushforth. There was also an
agent that the parties met with last fall that Barry might want
to go with and Devorah would be fine with working with him as
well. She just cannot remember his name. There is no money to put
into the house to "fix it up".

Fifth, neither Devorah or I want to have a file where one lawyer
writes one letter to have the file sit for two months while the
other lawyer writes another letter. We need a process to move
this matter forward. I suggest we set a date for a five way
meeting with Heidi Ruppert. I would like to set the date now.
Between now and then we can complete disclosure. The alternative
is that we send the parties to mediate with Heidi and to complete
disclosure with Heidi. This way they are paying one professional
not two. We could still set the five way in case the parties need
it.

I look forward to hearing from you.


Darrin L. Clayton Lawyer, B.A. (Hons.), J.D. (Juris Doctor)
Collaborative Family Law Lawyer