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from Steve Thomas deposition:

"Thomas depo 15 - Thomas and Darnay"
Q. You slipped once, maybe inadvertently, in referring to Darnay by Darnay as opposed to Mr.
Hoffman. When did Darnay Hoffman first contact you about his offer to represent you for free and to
absorb your legal cost in connection with the civil litigation filed against you by the Ramseys?

MR. DIAMOND: Can we just get a predicate that that fact occurred?
MR. WOOD: Yeah. I've got the New York lawyer, you know what I'm talking about, don't you,
MR. WOOD: For the record, you stated that several months prior months ofApril of 2001, you offered
to represent Steve Thomas pro bono, for free and absorb all of his legal costs, right?
MR. HOFFMAN: Yeah, at one point I did, yes.
Q. (BY MR. WOOD) Right. Tell me about that. When did he contact you?
A. I don't know. What's the date on the document you're looking at?
Q. Maybe Darnay can tell us that if you don't know.
MR. HOFFMAN: I don't remember that either.
Q. (BY MR. WOOD) But you know he called you? I don't know that --
MR. HOFFMAN: No, I did not call him.
MR. WOOD: How did you contact him?
MR. HOFFMAN: I sent him an e-mail. I don't have a phone number for --
THE REPORTER: Wait. One at a time.
MR. WOOD: E -mail, whatever. I'm not trying to -- I mean, you e-mailed him.
Q. (BY MR. WOOD) Did you get the e-mail, Mr. Thomas?
A. This today is the first time that I have ever spoken, correct me if I'm wrong, Mr. Hoffman, that I
have ever spoken personally to Mr. Darnay Hoffman.
Q. Thank you.
A. And yes, I do recall not only did he send me this e-mail but that on occasion I would be on an
e-mailing list that would receive e-mails from Mr. Hoffman.
Q. So it is true that Mr. Hoffman sent you, Steve Thomas, an e-mail in which he offered his legal
services to represent you for free, pro bono, and to absorb all of your legal costs in connection with any
litigation brought against you by the Ramsey family; is that true?
A. Very generously so, yes, he did.
Q. Why did you not accept it?
MR. DIAMOND: He had a better offer.
MR. HOFFMAN: Better lawyer, Lin. He got a better lawyer, trust me.
MR. WOOD: Why don't you all let Mr. Thomas figure out what to say about this, without being
MR. DIAMOND: Where is your sense of humor, Mr. Wood?
A. In addition to that e-mail --
Q. (BY MR. WOOD) Why don't you answer my question, Mr. Thomas?
A. I'm trying to, Mr. Wood.
Q. My question is why did you not accept it?
MR. DIAMOND: And you can continue.
Q. (BY MR. WOOD) Yeah, but please, just answer my question and we can move on to something
A. In another e-mail, Mr. Wood also e-mailed me the name and business address and telephone
number of a Mr. Daniel Petrocelli in Los Angeles who he also suggested as a fine attorney.
Q. Let me make sure we get that right. Mr. Wood didn't e-mail you Mr. Petrocelli's name. Are you
saying that Mr. Hoffman did?
A. Yes, my mistake, yes, that's what --
Q. But Mr. -- and was that close in time to his offer with respect to his offer to represent you?
A. I don't recall.
Q. Do you think it was a few days, a few weeks, a few months apart?
A. I don't recall the timing on either of these e-mails. Maybe Mr. Hoffman can help me out.
MR. WOOD: All I know, Darnay, is I've got your e-mail that you posted on April 1, 2001, where you
stated you made the offer to him several months before.
MR. HOFFMAN: Yeah, I don't remember exactly at what point after that I also suggested Daniel
Petrocelli who is, quite frankly, a better lawyer than I am in these areas, so.
MR. WOOD: Well, now we know how Dan Petrocelli gets some of his business. Let's go on to
something else.
MR. HOFFMAN: Through referrals, Lin, just like most lawyers.
MR. WOOD: Let's go on to something else.