Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1 :04-cv—01339-SLR Document 41-6 Filed 06/03/2005 Page 1 of 1
EXHIBIT E
Isaac M. Neuberger
From: Isaac M. Neuberger
Sent: Friday, August 27, 2004 1:04 PM
T0: Pamela Jarvis
Cc: Thomas M. Wood
Subject: RE: Applicability of Delaware Law
We are aware of this provision...it does NOT prevent the filing of a suit in North Carolina, does it'?
As to George's unfortunate "Iying through your teeth" comment, I am attaching the original set of e-mails, that
reflect his deliberate "bad faith"...these e-mails were followed by face to face discussions, where the Bs discussed
going as high as $7 MM.
Since it appears that Shamrock is unwilling to see its way clear towards an acceptable resolution, l suspect that
much of this will be the subject of discovery.
As we consider the alternatives, if we were to agree to the Delaware Mediation that you proposed, would we be
afforded the same discovery that we would be entitled if we proceed in a different forum.