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Does the Common Interest Doctrine Protect Third Party Funders from Accessing Privileged Information?

When it comes to the issue of disclosure of third party funders and their funding agreements, courts across the United States have consistently held that such information is protected under work product (some legislators have yet to catch on). That said, when it comes to the issue of sharing privileged information with a litigation funder, courts aren't as uniform in their findings. Some hold that the common interest doctrine protects privileged information that is passed on to a funder, and others have ruled the exact opposite. According to National Law Review, courts have been decidedly split on the issue of sharing privileged information with a third party funder - whether that be a prospective funder, or even one that is already contracted. In California, the district court in  Odyssey Wireless, Inc. v. Samsung Elecs. Co., 2016 U.S. Dist. LEXIS 188611 (S.D. Cal. Sept. 19, 2016) found that privileged documents disclosed to a funder do not wave work product, given the common interest that exists between third party funders and the plaintiffs (or in some cases defendants) they finance. However, in Berger v. Seyfarth Shaw LLP, 2008 U.S. Dist. LEXIS 88811 at *7-*8 (N.D. Cal. 2008), a separate district court found that the common interest doctrine does not apply to litigation funders, given that it was originally created to protect multiple litigants represented by a single counsel. Even though the doctrine is applied more broadly today, the court found that funders should not be covered under the umbrella of 'common interest.' Delaware has a similar discrepancy. In Carlyle Investment Mgmt. L.L.C. v. Moonmouth Co. S.A., No. 7841-VCP, 2015 Del. Ch. LEXIS 42 at *28-*30 (Del. Ch. Feb. 24, 2015), the state court found that common interest applies. However, in Leader Techs. Inc. v. Facebook, Inc., 729 F.Supp. 2d 373 (D. Del. 2010), the federal court disagreed, despite the fact that a written common interest agreement was in place between litigator and funder. All of this is quite head-scratching. But such is the nature of a common law jurisdiction when a relatively new enterprise emerges across the legal landscape. Unfortunately for funders, lawyers and claimants, the only thing we can be certain of going forward is that nothing is for certain. Case law remains unsettled, and the inconsistency on this issue arising from courtrooms across America will likely continue.

Woodsford Litigation Funding opens office in Tel Aviv

LONDON and TEL AVIV – Monday 25th March 2019, Woodsford Litigation Funding, the global provider of litigation financing solutions for businesses, individuals and law firms, has announced the opening of an office on Rothschild Boulevard in central Tel-Aviv. Woodsford has also announced the appointment of Yoav Navon as Director of Litigation Finance, Israel. Yoav was previously engaged by Woodsford as a Consultant. The office opening and the elevation of Yoav Navon, who has represented Woodsford in Tel Aviv for almost a year, illustrates Woodsford’s long term view of the potential for the Israeli market. Yoav Navon commented, “Having represented Woodsford in Israel for the past 10 months, I am now glad to have cemented my position at one of the leading global funders.  I can see the appetite for and understanding of the benefits funding offers is growing rapidly here.  We are already funding a number of Israeli parties in high stakes litigation, and we see real potential for growth, particularly in intellectual property litigation and international arbitration but in other areas too. ” “We are a growing, increasingly global business with a presence on both coasts of the US, the UK, Singapore and Australia. We engaged with Yoav last year as we believed there were a number of factors that made Israel another attractive and potentially lucrative market for us. With the opportunities we are now seeing in Israel, appointing Yoav to a permanent position and opening an office in Tel Aviv are the obvious next steps. Woodsford is looking to invest around $200m in 2019/20 in meritorious claims of all types, and we anticipate around 10% of that will be invested in Israeli claimants.” said Steven Friel, Woodsford’s CEO. About Woodsford Litigation Funding Founded in 2010 and with offices in London, Philadelphia Singapore and Tel Aviv, Woodsford Litigation Funding provides tailored litigation financing solutions for businesses, individuals, and law firms. This includes both single case and portfolio litigation funding, group action funding and arbitration funding. Woodsford’s Executive team blends extensive business experience with world-class legal expertise. Woodsford is a founder member of the Association of Litigation Funders of England and Wales. For further information visit http://www.woodsfordlitigationfunding.com or follow on Twitter @WoodsfordLF.
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Litigation Capital Management (AIM:LIT) announces global cooperation agreement with leading law firm

Litigation Capital Management Limited (AIM:LIT) (LCM), a leading international provider of litigation financing solutions, announces that it has entered into a global cooperation agreement with a leading international law firm.

The global cooperation agreement puts LCM in prime position to finance disputes undertaken by the law firm and its clients. LCM has agreed to make available access to significant funding for disputes as they arise for the law firm and its clients, regardless of geography or jurisdiction; that meet the Company’s rigorous due diligence process.

The law firm, which is headquartered in London, operates across six continents through a network of 50 offices and over 400 partners. The law firm is one of the most active in the litigation space globally and works with clients across sectors including aviation, energy and natural resources, infrastructure, trade and commodities, and insurance.

Patrick Moloney, Chief Executive Officer of LCM, said:

“We’re delighted to have agreed this global cooperation agreement with one of the leading law firms worldwide and one of the most active in the litigation space. The partners at the firm will have access to funding that LCM is providing, regardless of jurisdiction or geography.

“Our on-the-ground presence through offices in London, Sydney and Singapore allows us to support the law firm and its clients. This agreement will increase the number of potential funding opportunities available to LCM, in addition to our already substantial pipeline of investment opportunities, which we continually evaluate in line with our rigorous due-diligence procedures.”

About LCM Litigation Capital Management (“LCM”) is a leading international provider of litigation financing solutions. This includes single-case and portfolio across class actions, commercial claims, claims arising out of insolvency and international arbitration. LCM has an unparalleled track record, driven by effective project selection, active project management and robust risk management. Headquartered in Sydney, with offices in London, Singapore, Brisbane and Melbourne, LCM has been listed on AIM since December 2018, trading under the ticker LIT.
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Therium Exceeds $1 Billion Milestone In Latest Fundraise From Global Institutional Investors

Jersey, Channel Islands, 25 March, 2019. Therium Group Holdings Limited, a leading global provider of litigation, arbitration and specialty legal finance, today announced that it has exceeded an important $1billion milestone of funds raised, following a latest fund raise of £325 million from three global institutional investors, including a sovereign wealth fund, to finance litigation and arbitration globally. It is Therium’s largest fund and follows the £200 million raised in February 2018.

John Byrne, Co-Founder and CEO of Therium Capital Management Limited, said: “We are thrilled to announce the closing of our latest fund, Therium’s largest to date. Raising over $1 billion is an important milestone for the industry and underscores Therium’s leading position in the litigation finance industry globally. Interest from high quality institutional investors was stronger than ever, driven by the rapid growth of the firm, the very strong outlook for our business globally and our track record. We are delighted to have the backing of world leading institutional investors in our new fund and we are very excited about the ongoing high growth opportunity ahead for Therium, which is now in its 11th year.”

Neil Purslow, Co-Founder and Chief Investment Officer of Therium Capital Management Limited, said: “The demand for our litigation and arbitration funding continues at pace across all of our jurisdictions. The benefits of funding are becoming increasingly widespread across the world; from claimants that would not otherwise have the capital to launch their claims, to the largest corporates that use funding to transform claims into financial assets. In line with this, we are seeing a steady rise of single case funding as well as litigation and arbitration financing across multiple dispute types.”

Therium recently announced the opening of an office in Australia, to serve Asia-Pacific, where the firm has been funding cases since 2011. The firm also has investment teams in the UK, USA, Germany, Spain and Norway. Therium was the first commercial litigation funder to have operations on the ground in Germany and Scandinavia and it was the first European firm to launch a full service business in the US.

Therium will use the new funds to continue to invest in litigation and arbitration cases globally across sectors including financial services, energy and mining, industrials, technology, media and entertainment, and across all forms of commercial litigation and arbitration. Therium invests in a broad range of complex commercial disputes, from securities and shareholder actions, international arbitration, competition and anti-trust cases, through to intellectual property, insolvency and group and class actions. Furthermore, demand for Therium’s specialty legal finance solutions from corporates and law firms continues apace across jurisdictions. The new fund is expected to be deployed within two years.

In November 2018, Therium won the ‘Insolvency Litigation Funder of the Year’ award at the Turnaround Restructuring and Insolvency awards in London in recognition of its cross border insolvency funding expertise and leading track record.

In Chambers and Partners’ inaugural litigation support directory 2018, Therium was ranked as a Tier 1 litigation funder, and Neil Purslow was named a leading individual in the litigation funding industry. Therium is a founder member of the Association of Litigation Funders of England and Wales.

Last month, Therium Capital Management was top ranked as one of the two “Leading” litigation and arbitration funding firms in the UK by legal and business directory Leaders League, in their 2019 ranking of litigation funding. Therium was also ranked as “Excellent” in the 2019 US ranking

Case highlights, which are in the public domain, include:

  • Sharp and others v Lloyds Banking Group (re Lloyds’s acquisition of HBOS)
  • Noel Edmonds v Lloyds Banking Group
  • Consumers v VW re Dieselgate
  • Road Haulage Association v Truck manufacturers
  • Richard Lloyd v Google Inc (re data protection)
  • UK retailers v Mastercard and Visa (re interchange fees)
  • PCP Capital Partners v Barclays Bank plc
  • Bates & Ors v Post Office Ltd
  • Atlant Entreprenor v City of Oslo
  • Webb v GetSwift Ltd
  • Shareholders v Commonwealth Bank of Australia Ltd

About Therium

Therium is a leading global provider of litigation, arbitration and specialty legal finance active in England and Wales and internationally since 2009.  Over that period, Therium has funded claims with a total value exceeding £34 billion including many of the largest and most high profile funded cases.  The firm has investment teams in the UK, USA, Australia, Spain, Germany and Oslo, supplementing its resources in its corporate headquarters in Jersey, Channel Islands.

Therium has established a track record of success in litigation finance in all forms including single case litigation and arbitration funding, funding law firms and funding portfolios of litigation and arbitration claims.  This track record enabled the firm to raise the then single largest investment into litigation finance of £200 million in 2015.  The latest raise builds upon the previous raise of £200m which closed in only February 2018.

Therium has raised over $1 billion since its foundation, which includes the latest £325 million fund raised in March 2019.

Therium has consistently been at the forefront of innovation in litigation finance, pioneering the combined use of insurance tools alongside funding vehicles, and introducing portfolio funding products into the UK.  The firm’s ability to develop innovative funding arrangements and bespoke financial solutions for litigants and law firms complements its unmatched experience and rigorous approach to funding a wide range of commercial disputes throughout the world.

www.therium.com

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Balanced Bridge Reaffirms Their Commitment to Focus Exclusively on Post-Settlement Funding

ARDMORE, Pa.March 22, 2019 /PRNewswire/ -- Specialty finance firm Balanced Bridge Funding ("Balanced Bridge"), which offers to accelerate fees, awards, salaries, claims, contract earnings, and other future receivables across numerous asset classes, has made a commitment to focus the legal funding portion of their business exclusively on post-settlement funding. Virtually all legal finance companies concentrate their efforts on either pre-settlement advances or commercial litigation funding. "This is logical, as the vast majority of demand in the legal finance space exists within these categories," says Joseph Genovesi, CEO of Balanced Bridge. "However, there is still a demand for post-settlement advances, mainly for plaintiffs' attorneys, but also their clientele in certain scenarios where there is an extensive post-settlement payout delay. It is our goal to dominate this niche by providing affordable rates, transparent terms, and lightning fast turnaround." While it is true that some legal funding companies offer post-settlement advances to their clients in addition to their primary financial services, they are often unable to provide the full amount of capital required by the attorney or plaintiff requesting an advance. Because Balanced Bridge only focuses on settled case funding, they are uniquely equipped to offer the maximum advance amount as quickly as possible due to their streamlined underwriting process and large capital pool dedicated exclusively to financing post-settlement deals. "Balanced Bridge was created to provide financing to professionals with special funding requests not serviced by traditional lenders," says Patrick Conlin, Managing Director of Balanced Bridge. "We can provide fast financial relief to attorneys working on a contingency fee basis as well as their clientele by accelerating a portion of their delayed post-settlement receivables." Balanced Bridge purchases a portion of its clients' future receivables. In turn, they advance funds against the purchased amount, allowing the client to quickly access their money instead of becoming indebted to a lender. The result is a novel, fast, and affordable cash flow solution. The principals of Balanced Bridge, Joseph Genovesi and Patrick Conlin, have over 30 years of combined experience in the alternative finance space. Mr. Genovesi was the head of an alternative finance company. Prior to that, he served as president of a $200 million legal funding company and was the senior vice president at an alternative advisory firm. Mr. Conlin was an advisor to growth companies across multiple industries advising on matters related to mergers and acquisitions and raising capital. Are you a plaintiffs' attorney or plaintiff with a slow-paying settled case? Balanced Bridge is uniquely equipped to provide you the maximum advance amount possible with fair rates and transparent terms. To learn more about Balanced Bridge and its post-settlement funding solutions, please call 267-457-4540 to speak with one of their settlement funding specialists. You can also visit them on the web at https://www.balancedbridge.com, where you can submit an application for funding. Media Contact: 
Joseph Genovesi 
jgenovesi@balancedbridge.com 
267-457-4540 SOURCE Balanced Bridge Funding

Related Links

https://www.balancedbridge.com
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Burford Reaches FTSE-100 Status With Extraordinary Growth

After a recent 10% rise in share price, Burford Capital, the world's largest litigation funder, clocked in at a $4 billion valuation. That's enough to rank the company at the bottom of the FTSE-100, and many investors - including veteran fund manager Neil Woodford - feel that Burford is bound to rise even higher. According to City A.M., Burford announced that it has committed $2.6 billion to new investments over the past two years, double all of its cumulative prior commitments. The litigation funder also raised a massive $1.6 billion new fund, with most of that money coming from an unnamed sovereign wealth group. That capital will be deployed over the coming four years, according to the company. Last year, Burford maintained an operating margin of 84%, which helped the company achieve net profit growth of 24%, to $328 million. The company's return on equity was an impressive 30%. There is now some chatter about Burford de-listing from the AIM and perhaps moving to the LSE, where the stock will achieve even greater visibility. Time will tell if the funder decides to make that switch.

Litigation funding to double in five years as asset class becomes mainstream: expert

Litigation funding is undeniably becoming a mainstream asset class with the market set to double in the next five years. This is the prediction from Dilip N Massand of Legal Ventures, a UAE based fund by Phoenix Advisors that specializes in emerging markets. It is backed by Dalma Capital, a leading alternative investment manager.
Litigation funding takes place when a third party, with no direct interest in the proceedings, finances the cost of litigation in return for a share of the claim proceeds if the litigation is successful.
Mr Massand, who has over two decades of experience working on cross-border matters involving India, the Middle East, and the US, comments: “Depending on the jurisdiction, litigation funding is either about to become - or already is - a mainstream asset class.
“What is clear is the direction of travel: litigation finance is now undeniably emerging as a mainstream asset in its own right on a global level.” He continues: “In Australia, for example, the market is already heavily developed, but even the Australian market is expected to grow, owing to rising litigation demand for class actions. "The U.S., which currently accounts for around 40 per cent of all litigation funding, also remains a significant growth market primarily due to it being the largest litigation market. At 5 per cent, the UK is a considerably smaller but a highly attractive region for litigation funders being home to over 200 law firms and four of the top 10 global law firms. “Elsewhere, litigation funding for arbitration cases has been recently authorised in Singapore and Hong Kong. Whilst the Middle East, being a central hub for global trade, regularly sees substantial high-value disputes involving sophisticated entities and multiple jurisdictions. Most recently, significant discussion is taking place in India about the role litigation funding can play in making the resolution of domestic cases more efficient and providing access to justice for those who otherwise might not be able to afford it.” Besides the growing global reach of the sector, there are, says Mr. Massand, other major ‘pull factors’ for investors. “Clearly, the market itself has enormous potential for growth on a global scale, as ongoing and increasing regulatory reforms open the litigation funding market in many more regions. But there are other attractive elements compelling investors to invest in litigation funding. “These include uncorrelation to traditional capital markets, allowing for greater portfolio diversification – which is universally recognised as the investors’ best weapon to mitigate risk. In addition, there are outsized historical returns, and a reduced time to liquidity.” Indeed, a study by Professor Michael McDonald in 2016 on the litigation funding industry ROI indicated an average annual return of 36 per cent. “Given the market is expanding due to regulatory reforms in more global jurisdictions, the fact that there will always be legal claims, and that it represents an attractive alternative for investors, I am confident the litigation funding sector will double within the next five years. It will continue to extend itself into new jurisdictions in the emerging markets surrounding us in the UAE.” “As we enter the late stages of economic and credit cycles globally, sophisticated investors are increasingly seeking uncorrelated asset classes that can perform well in a market downturn” adds Zachary Cefaratti, CEO of Dalma Capital, “Litigation funding is a unique asset class in this regard; demand for litigation funding increases during downturns in the markets – a time when litigation spikes.” “As was the case in 2008, we expect the performance and opportunities for litigation funds to increase in the event of downturns and increasing market volatility.” About Dalma Capital: Dalma (DIFC) is an alternative investment accelerator and investment advisory firm focused on alternative investments and innovative financial products. The company primarily serves institutions, family offices and corporations - managing their alternative investments and advising on innovative financial products, including Islamic Investment Solutions, with a focus on Alpha generating strategies.
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Litigation Funding & The Invisible Gorilla

The following post was submitted by Dean Lipson, Partner of Covered Bridge Capital. Ever hear of the psychological experiment known as the Invisible Gorilla?[1]  It goes like this: You’re asked to watch a brief video of a group of people moving randomly about in a pack. Several of these people are wearing white shirts and passing a ball amongst themselves. You’re asked to count the number of passes that occur. During the video, a person dressed as a gorilla enters the middle of the pack and, while facing the camera, thumps his chest for a few seconds then exits. The video ends and you’re asked to give the number of times the ball was passed. Most likely, you get that right. You’re then asked if you saw the gorilla. Huh, what gorilla? Yes, despite being on-screen for 9 seconds, half of all participants in the experiment never see the gorilla. Ever hear of the lawsuit captioned Avery vs. State Farm?[2] It goes like this: 20 years ago, an Illinois jury awarded $456 million to plaintiffs in an action against State Farm for its use of inferior car parts in car repairs; conduct which violated State Farm’s own insurance policies. Following a finding of fraud, an additional $730 million was added to the verdict bringing the total to roughly $1.2 billion. That amount was then reduced to $1.01 billion on appeal. State Farm wasn’t done though. It filed yet another appeal, this time with Illinois’ highest court, which granted State Farm the ultimate victory: The verdict was completely overturned. The events of Avery gave rise to a second suit against State Farm. In Hale vs. State Farm[3], the Avery plaintiffs alleged State Farm had not only orchestrated the recruitment of Lloyd Karmeier but also had secretly bankrolled his successful bid to be become an Illinois Supreme Court Justice in 2004[4]. Why? Because the Avery case was on appeal at that time and Justice Karmeier would now be available to influence its fate, which is precisely what happened.  Hale was filed in 2012 and it alleged the events leading up to, and following, the Karmeier election violated the Racketeer Influenced and Corrupt Organizations Act (RICO). Again, the assertion here was that State Farm had organized and managed Karmeier’s campaign behind the scenes; that State Farm had covertly funneled millions of dollars to support the campaign through intermediary organizations over which State Farm had exerted considerable influence. Hale dragged on for 6 years before settling in 2018 for $250 million. The settlement was approved on the basis that only one of roughly 5 million plaintiffs objected. Well, with the claim now going into its 20th year and with individual net recoveries averaging less than $50, it’s a wonder anyone made the effort to object. It’s unfortunate Hale settled and the public was denied a look behind the curtain. Still, the circumstantial evidence is ample and more than enough to suggest the insurance giant pulled strings and levered its enormous influence to achieve that which it could not before a jury.  That’s a huge problem. But we have an even bigger problem: you and me. The State Farms of the world will always rent-seek and will always attempt to change the rules of the game to ensure their victory. We know this. The problem is that you and I aren’t doing enough to stop our country’s seemingly inexorable slide from democracy into corporatocracy?  We’ve become jaded, resigned, disenfranchised and, according to experts, blind; blind to what’s around us and blind to the very fact of our blindness.[5] That’s the takeaway from the Invisible Gorilla experiment. We come to litigation funding. The naysayers want to frame it as a problem but it is in fact a solution born of a problem. Corporate America continues to accumulate power while you and I continue to lose ours in this zero-sum battle. Isn’t that the real problem here? Come on, don’t you see the gorilla standing right in front of you thumping his chest? Dean Lipson Covered Bridge Capital, LLC “The greatest enemy of knowledge is not ignorance, it is the illusion of knowledge” -Stephen Hawking -- [1] www.theinvisiblegorilla.com [2] https://www.bloomberglaw.com/public/desktop/document/AveryvStateFarmMutAutoInsCo321IllApp3d269254IllDec194746NE2d1242A/1?1552679577 [3] https://www.bloomberglaw.com/public/desktop/document/HalevStateFarmMutAutoInsCoNo120660DRH2018BL462903SDIllDec132018Co?1552677329 [4] In the most expensive judicial election in United States history to that point, Justice Karmeier won the open seat. Ahem, he beat Appellate Judge Gordon Maag who wrote the Avery Appellate Court opinion against State Farm. [5] www.theinvisiblegorilla.com
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Litigation Finance Primer

SPONSORED POST: Litigation Finance Opportunity for ‘David vs. Goliath’ Case

Loewinsohn Flegle Deary Simon is prosecuting a claim valued at $31m. We are raising $2.3m for return within 12 months, possible additional upside. $450k to close, balance on run rate 30 days net to trial. The claimant is a single individual plaintiff who is a very credible former investment banker. Claimant is very knowledgeable and is committed to conclusion of the claim. One defendant is a large international financial institution and the second defendant is a highly liquid mortgage loan originator. Case documents are structured finance and real estate. Defendant’s counsel is a national general practice firm, lead defense counsel is 4-year partner. This is a complex financial claim, fact intensive, document case. Documents we hold support an opinion letter from a legal 500 firm at 80% chance of recovery. Damages are supported by preliminary economic expert and other case documents. Why we believe we will win This case arises out of a fraudulent foreclosure on plaintiffs' home. The Financial Conduct Authority (FCA) regulated plaintiff who  has brought claims that will likely result in a verdict including actual damages of $31,880,288.014 for Breach of Contract, Fraud, Fraudulent Lien Against Real Property, Deceptive Trade Practices Act (“DTPA”) and Texas Debt Collection Act (“TDCA”).  Claimant was not in default, and allegations made against the plaintiff are proven to be false. The court records contain perjured statements, forged robo-signed affidavits, assignments, fraudulent liens, fraudulent appointment of substitute trustees and many other records. Defendants fraudulently concealed its lack of interest in the property by manufacturing evidence. These false allegations destroyed plaintiff’s credit, caused property loss, loss ofreputation and career. The jury will likely return a substantial verdict on the TDCA, which is a treble damages statute. It is important to note that the jury will not be advised that  fraud finding results in an automatic trebling of actual damages and mental anguish under both the DTPA and TDCA. The Court’s judgment could be set at over $69,131,398.50.   Three of the four claims allow for the recovery of attorneys’ fees. In sum, the fraudulent conduct by Defendants supports “uncapped” exemplary damages. Given the result obtained by the Loewinsohn Firm against JP Morgan Chase last year, defendants have a powerful incentive to settle this case for close to the full amount of damages. A Full litigation plan illustrates solid case of merits, liability, and damages for each claim. Plan includes analysis of defenses and key arguments. Data room is set up for due diligence. Case is on file in state court, no DCO or trial date. Preferential date will be requested within approximately 9 months. A Motion to dismiss was filed and denied. About Loewinsohn Flegle Deary Simon Loewinsohn Flegle Deary Simon have extensive experience representing clients ranging from Fortune 500 companies to individuals on both sides of the docket in complex business, employment and bankruptcy disputes. The firm’s recent successes include two high-profile cases. In July 2018, an LFDS team including Craig Simon, Alan Loewinsohn, Matt Ray and Jennifer Barall secured a $45 million settlement on behalf of Navajo Transitional Energy Company in a contract dispute against a number of public utilities.  Last year, partners Alan Loewinsohn, Jim Flegle and Kerry Schonwald represented their client Jo Hopper in a breach of trust case against J.P. Morgan Chase & Co., where a Dallas probate jury awarded $6.014 billion in damages, the largest jury verdict in the United States in 2017 and the ninth largest verdict in US history. The trial lawyers at Loewinsohn Flegle Deary Simon are nationally recognized, including most recently on Friday of last week, by editors and reporters of American Lawyer Media’s National Law Journal as the top law firm in the Nation for 2018, Elite Trial Lawyers Business Torts category. The facts and evidence to date suggest that we could achieve a similar outcome and damages to our record judgment in Hopper. We are new to litigation funding. Our view is this case is suited to Family Office, Special Situations Fund, Individual investor, joint venture with another law firm, or Hedge Fund. Xpress your interest by emailing Alan Loewinsohn AlanL@lfdslaw.com Loewinsohn Flegle Deary Simon LLP 12377 Merit Drive, Ste 900 Dallas, Texas 75251 214 572 1707 www.lfdslaw.com
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