Oy vey, he's back! Dancing with Murray - yet again!

POSNER & TRACHTENBERG
Barristers, Solicitors & Notaries Public
710-491 Portage Avenue
Winnipeg, MB R3B 2E4
Fax: 944-8878

Gerald S. Posner
Manitoba & Ontario Bars

Murray N. Trachtenberg
B.A., LL.B.
Direct Line: (204) 940-9602
e-mail: mtrachtenberg@ptlaw.mb.ca
_____________________________________________
February 14, 2008

Mr. Clare L. Pieuk
2 - 371 Des Meurons Street
Winnipeg, Manitoba R2H 2N6

Dear Mr. Pieuk:

Re: MMF et al vs. Clare L. Pieuk et al
Queen's Bench File no. CI 05-01-41955
My File No. 2003-20

This is further to my letter of January 4, 2008. You still have outstanding undertakings from your examination for discovery. You have had ample time to respond and provide the documentation/information you agreed to produce. Please comply with your undertakings in the very near future.

Yours truly,
MURRAY N. TRACHTENBERG
MNT/lec
--------------------------------------------------------------------------
WITHOUT PREJUDICE

February 22, 2008

Mr. Murray Norman Trachtenberg
Posner & Trachtenberg
710-491 Portage Avenue
Winnipeg, MB R3B 2E4
Fax: (204) 944-8878

Dear Counselor Trachtenberg:

Unlike you who has unlimited access to Canadian taxpayer dollars via the publicly funded Manitoba Metis Federation, I must work every day to make an honest living.

Regarding Undertaking 1:

From: "Lionel Chartrand" lrc@shaw.ca
To: "Clare Pieuk" pieuk@shaw.ca; "Vanessa Everton" veverton1@shaw.ca
Sent: January 21, 2004 1:35
Attach: WMA20040121.PETITION.doc
Subject: Re: CyberSmokeSignals

Hi Clare,

Here is a quick draft petition. If you and Vanessa like it, please feel free to use and in whatever context you like. I don't need to have credit for it.

If you prefer it come from me, (it may be better that it doesn't) then perhaps post it along with a letter something like this:

Dear Readers:

I have been receiving requests to draft a petition to the governments on behalf of the Metis requesting that they do not give the MMF any mre funding until the MMF has cmplied with the court order. I am responding with a draft petition according to the instructions given to me by (Metis Mom) -or- (a Federation member) -or- (an MMF member who requested their identity not be disclosed).

Please feel free to amend the draft petition as you see fit.

Then there was this Counselor Trachtenberg:

From: "Lionel Chartrand" lrc@shaw.ca
To: "Clare Pieuk" pieuk@shaw.ca
Sent: February 20, 2004 9:33 AM
Subject: CSS

Hi Clare,

I met with the lawyer appointed by the Law Society for me yesterday and he would like, if this is possible, data as to how many hits on CSS there were from February 5th to 10th, and also if obainable, how many hits were repeat hits from the same IP address, i.e. total number of people who could have viewed my letter. If Terry is the one with that info available, could you pass on this request to him?

Thanks,
Lionel

Please note Counselor Trachtenberg, it was on or about this time Mr. Lionel R. Chartrand in a late evening telephone call requested I remove all his e-mail correspondence to me. Fortunately, I had the presence of mind not to do so.

While I continue to diligently search, I am temporarily unable to find the e-mail attachment from Lionel R. Chartrand entitled WMA20040121. PETITION.doc.

Here, Sir, are your options:

(1) You can contact Co-Defendant Terrance Paul Belhumeur who has exclusive ownsership of www.CyberSmokeSignals.com and controlled all material posted on that site. He has a copy

(2) Contact Vanessa Everton who was removed as a Co-Defendant last year after signing a letter stating she was unaware of any malfeasance on the part of the Manitoba Metis Federation

(3) In the alternative, my former attorney Mr. Jeffrey J. Niederhoffer would not object to being deposed as a third-party. However, I am only prepared to waive client-solicitor privilege in regard to this narrow issue and nothing more subject to the conditions:

(i) As a third-party Examination for Discovery, I am NOT consenting to Mr. Niederhoffer being questioned on any other matter related to this lawsuit

(ii) He can be questioned ONLY on issuses related to Mr. Lionel Chartrand's preparation of the alleged defamatory petition which appeared on www.CyberSmokeSignals.com late in January, 2004

(iii) Mr. Niederhoffer's knowledge of Lionel R. Chartrand's involvement providing advice to www.CyberSmokeSignals.com in his capacity as its General Legal Council

Failure to compy with any of these conditions immediately renders this understanding null and void.

Rest assured Mr. Trachtenberg I will continue to exercise due diligence and make every effort to find this misplaced document.

Please govern yourself accordingly Counselor.

Sincerely,
Clare L. Pieuk

Distribution List
philipslayton@hotmail.com
mtrachtenberg@ptlaw.mb.ca