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PCR Exhibits - Alaska State of Corruption

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OSTERMAN: That’s right. I mean they’re like anybody else. They don’t want to read<br />

garbage.<br />

HAEG: Ok.<br />

OSTERMAN: So we – we – we’re trying to spruce up the facts to make it a chitleread<br />

() As I recall we got about 12 pages <strong>of</strong> facts and I think after I talked to Joel and – and we<br />

looked back at it we’re down to about 7 or 8 pages now <strong>of</strong> facts which is pretty good. Uh…<br />

(01:23)<br />

HAEG: And what do you mean the facts Like <strong>of</strong> us going out and doing what we did or<br />

what<br />

OSTERMAN: Well yeah if you’ll remember the very beginning <strong>of</strong> that we have to recite<br />

to the court what happened. And then what happened in court. Now one <strong>of</strong> the things<br />

that’s not necessarily in the statement <strong>of</strong> facts deals with what happened<br />

with Cole – necessarily.<br />

HAEG: Ok.<br />

OSTERMAN: Because the – the whole – the whole fact is we need to convince three<br />

members <strong>of</strong> the Court <strong>of</strong> Appeals this thing ought to be reversed. That there’s been an injustice<br />

done. And the only way we can get that flavor to them is that we describe it. Ok. Case law be<br />

damned if we don’t take care <strong>of</strong> the facts <strong>of</strong> the case and make this an easy read for them. They’ll<br />

sacrifice us at the alter <strong>of</strong> stupidity. Ok<br />

HAEG: Ok.<br />

OSTERMAN: So I need your input in this if you can get it to me by the end <strong>of</strong> the week.<br />

HAEG: Ok.<br />

OSTERMAN: With that we want this thing just simply a matter <strong>of</strong> the mechanics. We<br />

want – we have to go through – let me – bear with me – if you look at the bottom <strong>of</strong> each<br />

footnote you’ll see a statement that just simply says citation. Or makes some reference to a<br />

hearing transcript. Well we’ve got to go through it and augment it – supplement it. And we also<br />

have to create a table <strong>of</strong> statutes, a table <strong>of</strong> um <strong>of</strong> cases, a table <strong>of</strong> authorities – generally, an<br />

additional table <strong>of</strong> authorities and then we’ve got to re-footnote everything and we got to run a<br />

master on the footnote for locations under a table <strong>of</strong> contents. So we’ve got a lot <strong>of</strong> mechanical<br />

155

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