. The allegations made in the Motion (5:12-7:10) as to the duties of and
compensation to employee Janet Neal is rife with
inaccuracies and mischaracterization of prior
testimony. For example, the allega
tion that “TPL paid Ms. Neal
far more than the compensation
listed in her written consulting agreement....”
(Motion, 6:8-10) is entirely unsupported. The
only thing that the OCC did cite
is Exhibit “C” to the Kim decl
aration - a copy of Ms. Neal’s
consulting agreement - which provides no support fo
r the statement that she was paid “far more”
than in her agreement.. The OCC’s reference
to Exhibit “A” of Ms Kim’s declaration is
unavailing as well as an attempt to support their
statements, inappropriately suggested as fact,
that TPL loaned money for Ms. Neal to purchas
e her home. The Exhib
it contains nothing but
unequivocal testimony by Dwayne Hannah that TPL
did not provide any funds for Ms. Neal’s
home. [1198:16-28.] No money was ever loan
ed by TPL to Ms. Neal for her home. The
statement made by the OCC that they do not know
what Ms. Neal does is supported only by a
declaration from the OCC’s attorney, Mr. Murray,
who has never met nor worked with Ms. Neal.
TPL is prepared to refute the OCC’s remaining
attacks on its employment of Ms. Neal, point-by-
point, at an evidentiar
y hearing on the Motion.
2.
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