Supplemental Exhibit

June 20, 1986

 

Larry Drivon files a Supplemental Exhibit, his Letter of Intent to Withdraw dated December 5, 1984, on the morning of the hearing in the matter.* Judge Raymond D. Williamson, Jr. has an 8:30am calendar thereby excusing him from releasing Larry in view of the fact that Larry said in his letter that it would be in the best interests of my case that he withdraw 1.5 years earlier, before "we are farther down the line and additional tactical decisions have been made which might be different than those made by another firm handling this matter." Drivon ends his letter assuring me that he wants to "obviate" the successful completion of this matter on my behalf.** The judge would not see this nor would he learn prior to the hearing, on the record (wink wink, nod nod) that Larry decided instead to double his stay on the case from 1.5 to 3 years, and contrariwise, not to "schedule Haig's deposition in this matter and then force the matter as quickly as possible to trial."

Larry's stay on the case for the additional 1.5 years served the following purpose. Should something requiring Larry to be my unequivocal legal counsel making a "tactical decision" on my behalf actually occur, then the on-record absence of the Letter of Intent to Withdraw would serve its purpose. One such significant happenstance would prove to be my father, Vasken Berberian's, unexpected death on January 24, 1985. It is my belief that for mostly this reason, my father's death, Larry stayed on as my legal counsel for the additional year and a half. Of course, this tactical decision or strategy was never verbalized to me. I would figure this out after the fact when I could see things more clearly and without as much in-the trenches emotion involved. Though not directly connected to his decision to withhold the filing of his Letter of Intent (something I wouldn't find out until his actual withdrawal, his having led me to believe that it was on record since the time of his mailing me an un-file-stamped copy of it), another tactical decision Larry would make would be his failure and refusal to take the deposition of Haig Berberian despite my urging him to do so. The question remains, why? He also failed to take the deposition of my father, Vasken Berberian, prior to my father's death. My father was to be my star witness. What he did do instead, I assume, was to make a cassette recording of a meeting Larry had with my father and I. Upon Larry's withdrawal, and after I requested a copy, he would deny making any such recording. The question remains, why? The answer is the stuff with which conspiracies and their hidden agendas are made.

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*This is one of the many and varied tricks of the attorney trade. I will point out many more tricks, sleights of hand, bill of goods sold, head-fakes and selling of snake oil throughout the course of this exposé regarding Berberian v. Berberian & Wells Fargo Bank, my case being particularly pregnant with such deceptions.

**The attorney who helped me contest Larry Drivon's withdrawal pointed out to me as he circled the word on a copy of the letter, that "obviate" was a curious word to use in the last sentence (or any sentence for that matter) of the Notice of Intent to Withdraw letter wherein Larry said that he would help me in any way he can to find successor counsel. The judge would not see (on the record) any of the information in Drivon's letter nor the memorialized intentions therein, prior to nor in the context of the decision the judge was ruling upon. This was, of course, the intention of the tactical late filing.

 

Click here to view the Supplemental Exhibit