EXHIBIT A

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 1 of 10
1

From: Casper, Michelle <MCasper@salawus.com>

Sent: Wednesday, December 13, 2017 7:09 AM

To: 'Ray Gupta'

Cc: Charnowski, Elizabeth; 'Danica Blecic'

Subject: RE: Lockhart - best and final offer [IWOV-Active.FID473960]

That’s great news, Ray – thank you. We will hold the settlement amount firm pending your discussions with the

lienholder and bankruptcy court. In the meantime, I will prepare a draft Release and we can fill in the lien information

once that is finalized. Keep me posted and thank you for working to settle this one.

Michelle

_________________________

Michelle L. Casper

Partner – Licensed in Ohio, Indiana and Ilinois

SmithAmundsen LLC

Local office: New Albany, Ohio | Firm Headquarters: 150 North Michigan Avenue, Suite 3300, Chicago, Illinois 60601

Phone (312) 894-3341 | Fax (312) 894-3210 |  mcasper@salawus.com |  http://www.salawus.com

Please consider the environment before printing this e-mail

This message is intended only for the individual or entity to which it is addressed and may contain information that is attorney work product, privileged,

confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that

any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us

immediately by telephone and return the original message to us at the above address via email or the United States Postal Service. Thank you.

From: Ray Gupta [mailto:ray_gupta@yahoo.com]

Sent: Tuesday, December 12, 2017 9:13 PM

To: Casper, Michelle

Cc: Charnowski, Elizabeth; 'Danica Blecic'

Subject: Re: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Michelle, thanks for reconsidering.

After speaking with Sheila, she WILL ACCEPT accept but please leave open through at least

December 22 since I STILL have not heard from lienholder and bankruptcy court. (I am not sure I will

know something by then, but I am hopeful).

Ray Gupta

Ray Gupta & Associates, LLC

833 West Lincoln Highway

Suite 380 E

Schererville, Indiana 46375

219-923-5839 (PHONE)

219-227-8209 (FAX)

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 2 of 10
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From: "Casper, Michelle" <MCasper@salawus.com>

To: 'Ray Gupta' <ray_gupta@yahoo.com>

Cc: "Charnowski, Elizabeth" <ECharnowski@salawus.com>; 'Danica Blecic' <DBlecic@rayguptalaw.com>

Sent: Saturday, December 9, 2017 9:31 PM

Subject: RE: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Ray,

Thank you for speaking with me last week about this case. I spoke with my client and they are unwilling to increase the

offer beyond $100,000. We believe in the strength of our case and are comfortable taking it to a jury. The best and final

offer is $100,000 and will remain open until this Friday, December 15, 2017.

I look forward to hearing from you.

Best regards,

Michelle

From: Casper, Michelle [mailto:MCasper@salawus.com]

Sent: Thursday, November 30, 2017 3:31 PM

To: 'Ray Gupta'

Cc: Charnowski, Elizabeth; 'Danica Blecic'

Subject: RE: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Ray,

I will chat with my client about leaving the offer open for a week or two more, but will probably need to motion the

Court for an extension on the remaining discovery dates as our Daubert Motions are due in early 2018. I think if we can

show that you’re working to resolve the lien issues, the judge will give us some leniency.

Has Ms. Lockhart filed for bankruptcy?

Michelle

_________________________

Michelle L. Casper

Partner – Licensed in Ohio, Indiana and Ilinois

SmithAmundsen LLC

Local office: New Albany, Ohio | Firm Headquarters: 150 North Michigan Avenue, Suite 3300, Chicago, Illinois 60601

Phone (312) 894-3341 | Fax (312) 894-3210 |  mcasper@salawus.com |  http://www.salawus.com

Please consider the environment before printing this e-mail

This message is intended only for the individual or entity to which it is addressed and may contain information that is attorney work product, privileged,

confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that

any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us

immediately by telephone and return the original message to us at the above address via email or the United States Postal Service. Thank you.

From: Ray Gupta [mailto:ray_gupta@yahoo.com]

Sent: Thursday, November 30, 2017 3:20 PM

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 3 of 10
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To: Casper, Michelle

Cc: Charnowski, Elizabeth; 'Danica Blecic'

Subject: Re: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Michelle, we are still working on outstanding medical bills liens and trying to get them reduced.

Also, the bankruptcy court is involved and evaluating what they will accept.....

Can you continue to leave the offer open while I try to work through these outstanding issues?

Ray Gupta

Ray Gupta & Associates, LLC

833 West Lincoln Highway

Suite 380 E

Schererville, Indiana 46375

219-923-5839 (PHONE)

219-227-8209 (FAX)

From: "Casper, Michelle" <MCasper@salawus.com>

To: ray_gupta <ray_gupta@yahoo.com>

Cc: "Charnowski, Elizabeth" <ECharnowski@salawus.com>; 'Danica Blecic' <DBlecic@rayguptalaw.com>

Sent: Thursday, November 30, 2017 11:44 AM

Subject: RE: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Ray,

I hope you had a nice Thanksgiving. I’m following up on our settlement offer. Could you please let me know your client’s

response as soon as possible? We have upcoming deadlines and I will need to start actively working on this case if we

cannot reach settlement. Please let me know if your client will accept our offer by tomorrow. Thanks – and reach out

with any questions.

Michelle

From: Casper, Michelle

Sent: Monday, November 20, 2017 11:19 AM

To: ray_gupta

Cc: Charnowski, Elizabeth

Subject: Lockhart - best and final offer [IWOV-Active.FID473960]

Hi Ray,

I finally heard from my contact at Precision Pipeline. Their best and final offer is $100,000.00. I know you have several

liens and high expenses for your experts, but this offer accounts for our valuation of the case. Please discuss with Ms.

Lockhart and reach out with any questions. I hope you had a nice weekend and talk soon.

Thanks,

Michelle

_________________________

Michelle L. Casper

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 4 of 10
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Partner – Licensed in Illinois, Indiana and Ohio

SmithAmundsen LLC

150 North Michigan Avenue, Suite 3300 , Chicago , Illinois 60601 | Local office: New Albany, Ohio

Phone (312) 894-3341 | Fax (312) 894-3210 |  mcasper@salawus.com |  http://www.salawus.com

Please consider the environment before printing this e-mail

This message is intended only for the individual or entity to which it is addressed and may contain information that is attorney work product, privileged,

confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that

any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us

immediately by telephone and return the original message to us at the above address via email or the United States Postal Service. Thank you.

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 5 of 10
EXHIBIT B

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 6 of 10
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From: Casper, Michelle <MCasper@salawus.com>

Sent: Wednesday, December 13, 2017 7:20 AM

To: 'cash@pchael13.com'

Cc: 'Ray Gupta'

Subject: Sheila Marie Lockhart (Case #14-21307-jra) - personal injury settlement [IWOVActive.FID473960]

Hi Paul,

I represent several defendants in a personal injury action brought by Sheila Lockhart. I have reached settlement with Ms.

Lockhart’s attorney, Ray Gupta, in the amount of $100,000.00. I understand the pending bankruptcy action with Ms.

Lockhart requires the Court to approve the settlement and distribute a portion of the settlement amount to Ms.

Lockhart’s creditors (or as repayment to her current plan). Please let me know what you need from me. My clients

would like to work to finalize the settlement sooner rather than later.

Thanks for your help.

Best regards,

Michelle

_________________________

Michelle L. Casper

Partner – Licensed in Ohio, Indiana and Ilinois

SmithAmundsen LLC

Local office: New Albany, Ohio | Firm Headquarters: 150 North Michigan Avenue, Suite 3300, Chicago, Illinois 60601

Phone (312) 894-3341 | Fax (312) 894-3210 |  mcasper@salawus.com |  http://www.salawus.com

Please consider the environment before printing this e-mail

This message is intended only for the individual or entity to which it is addressed and may contain information that is attorney work product, privileged,

confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that

any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us

immediately by telephone and return the original message to us at the above address via email or the United States Postal Service. Thank you.

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 7 of 10
1

From: Drew Rhed <office@rhedlaw.com>

Sent: Friday, December 15, 2017 8:30 AM

To: Casper, Michelle

Subject: Re: Lockhart - Settlement [IWOV-Active.FID473960]

No problem. I have not spoken with their office. I believe my assistant set a telephone conference with them for

today. I will keep you informed as I can. Thank you for your response. Have a great day.

Drew

On Fri, Dec 15, 2017 at 8:24 AM, Casper, Michelle <MCasper@salawus.com> wrote:

Hi Drew,

I emailed the bankruptcy trustee (Paul Chael) but perhaps he forwarded my email to you? Ray Gutpa, the attorney in the

personal injury case, had informed me that he spoke with you. I apologize for not reaching out directly! The agreedupon settlement by Plaintiff and Mr. Gupta is for $100,000. Thank you for reaching out and let me know how I may

assist further.

Best regards,

Michelle

_________________________

Michelle L. Casper

Partner – Licensed in Ohio, Indiana and Ilinois

SmithAmundsen LLC

Local office: New Albany, Ohio | Firm Headquarters: 150 North Michigan Avenue, Suite 3300, Chicago, Illinois 60601

Phone (312) 894-3341 | Fax (312) 894-3210 |  mcasper@salawus.com |  http://www.salawus.com

Please consider the environment before printing this e-mail

This message is intended only for the individual or entity to which it is addressed and may contain information that is attorney work product, privileged,

confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 8 of 10
2

any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us

immediately by telephone and return the original message to us at the above address via email or the United States Postal Service. Thank you.

From: Drew Rhed [mailto:office@rhedlaw.com]

Sent: Thursday, December 14, 2017 11:36 AM

To: Casper, Michelle

Subject: Lockhart - Settlement

Re: Sheila Marie Lockhart

14-21307-jra

Personal Injury Settlement

Ms. Casper,

I appreciate you informing me of the Settlement that has been entered. I have not spoken with my client or her

attorneys as to this yet. I will confirm with them the terms. The process will be that I will need to file a Motion

to Compromise and Settle. I should not nor should the Trustee's office need anything from your office at this

time. I should be able to get the information from Mr. Gupta's office. I have not heard from them as to the

Settlement but will be reaching out to them today as well. I will need a copy of the settlement paperwork. I

have an Order Granting the Application to Employ already. I will look to file the Motion to Compromise as

soon as possible. Thank you. Feel free to contact me or my office for any type of follow up or status.

Drew Rhed

--

Drew C. Rhed, LLC

101 Beverly Drive, Ste. B

Chesterton, IN 46304

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 9 of 10
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219.359.3161 phone

219.359.3171 fax

office@rhedlaw.com

********************************************************************************************

CONFIDENTIALITY NOTICE

This message is confidential, intended only for the named recipient(s) and may contain information that is privileged,

attorney work product, or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are

notified that the dissemination, distribution or copying of this message is strictly prohibited. If you received this message in

error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any

copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client

work product or other applicable privilege. Thank you.

********************************************************************************************

DISCLOSURE REQUIRED BY CIRCULAR 230

The foregoing correspondence was not written or intended to be relied upon, nor can it be used, by any taxpayer for the

purpose of avoiding Federal Tax penalties. This disclaimer is made to comply with Circular 230 which governs practice

before the Internal Revenue Service.

--

Drew C. Rhed, LLC

101 Beverly Drive, Ste. B

Chesterton, IN 46304

219.359.3161 phone

219.359.3171 fax

office@rhedlaw.com

********************************************************************************************

CONFIDENTIALITY NOTICE

This message is confidential, intended only for the named recipient(s) and may contain information that is privileged,

attorney work product, or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are

notified that the dissemination, distribution or copying of this message is strictly prohibited. If you received this message in

error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any

copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client

work product or other applicable privilege. Thank you.

********************************************************************************************

DISCLOSURE REQUIRED BY CIRCULAR 230

The foregoing correspondence was not written or intended to be relied upon, nor can it be used, by any taxpayer for the

purpose of avoiding Federal Tax penalties. This disclaimer is made to comply with Circular 230 which governs practice

before the Internal Revenue Service.

USDC IN/ND case 2:15-cv-00445-JPK document 39-1 filed 01/17/18 page 10 of 10