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TO: A.A. Dewey
Iain M. Cheatem, Q.C.
FR: Edwin Dewey
Date: January 22, 2003
RE: Baggins Cases
Please be advised that my secretary has been given her
two week notice. Linda is a darling girl, but when she
told me that "I thought we always represented the person
on the top of the caption" I simply had to find someone
else. Because we are at once handling the incorporation
matter for the Fellowship (matter #04456), the criminal
case pending against Mr. Baggins (matter #22213), as
well as the quiet title action brought by Sauron (matter
#66555), I can understand why she might be confused.
Still, there's no excuse for this and corrective action
has been taken.
I have been informed by counsel for Sauruman Lord of
Orthanc that he intends to file an Intervention in the
Quiet Title action as a Real Party in Interest. Extensive
research by associates, as well as a thorough search
by a Title Insurance Company have revealed no proprietary
interest in the ring. We must assume that Sauruman intends
to press his claim not as an individual or in his capacity
as Lord of Orthanc, but as a member of the Istari, which
wizards being the designated representatives of Valinor
in Middle Earth may possibly be able to assert eminent
domain over the Ring.
We have also been served with ex parte notice by Mr.
Crebain in the related property dispute over certain
territories in Eastern Gondor (matter #00887). It appears
that Mr. Crebain is asking the Court to continue the
summary judgment proceeding on the fifth count (Dec
relief re: riparian rights), the fourth count (trespass),
and the eighth count (replevin of Osgiliath). The papers
Crebain served indicate that one of his witnesses, the
former Witch-King of Angmar, is unavailable. Mr. Crebain
intends to present evidence that the Witch King issued
several dying declarations, which we may contest later.
I've instructed one of our associates in the Dol Amaroth
office to attend this hearing and present our opposition.
I've also opened up a new case matter for a personal
injury suit. The Lady Eowyn of Rohan has filed suit
against Sauron for personal injury, as well as emotional
and punitive damages. It appears that she's done something
to her arm. The file sent to us includes a declaration
from the Plaintiff in the Gondorian Succession dispute
enumerating the Lady Eowyn's medical costs. Could one
of you please have word processing run a conflict check?
Finally, I've not gotten back to you because I had to
attend a deposition in Mordor (see my January 3 memo
re: Enforcement of Judgment) which should be the last
discovery prior to trial in the False Imprisonment action
brought by Gollum in the Courts of Mirkwood. I've checked
to ensure that our representation of the Elven Kingdom
won't interfere with our representation in the other
matters described supra.
While I was in Mordor, I had a chance to stop by the
local constabulary to visit our client. Sometimes working
on the ground can be useful. I obtained delcarations
by two of the Correctional employees as Cirith Ungol
stating that they released Mr. Baggins on his own recognizance
following a prison riot. In return I promised them we
would file a habeus action to see if we couldn't pull
them out of jail. Any of our Of Counsel free to attend
to this matter? Maybe a junior associate would like
a chance to work on a "sexy" criminal case.
Thanks for all your hard work, and sorry for the confusion.
-Edwin