individual customers and to memorialize their agreement in writing. Lovasz claims that Kennard instead ordered all of their joint accounts transferred to Feinberg, leaving Lovasz with no customer accounts. Lovasz also claims that Feinberg offered Lovasz twenty percent of the commissions on their formerly joint accounts if Lovasz would not make trouble for Feinberg and would testify in such a way as to back up Feinberg's story.
On October 31, 1985, Lovasz called Kempner's counsel, Felice Mischel ("Mischel") and told her of Feinberg's alleged forgery, Oppenheimer's counsel's alleged microfiche destruction and Kennard's alleged entreaties to commit perjury. Mischel dispatched a letter to the Court, Magistrate Buchwald and the Departmental Disciplinary Committee advising them of Lovasz's allegations.
On November 4, 1985, Lovasz met with Kleinberg. Kleinberg prepared a contemporaneous memorandum ofabout any of these matters. Oppenheimer also contends that Lovasz was notified immediately thereafter by letter of his termination.
After his termination, Lovasz met with Oppenheimer and the Gold firm. Oppenheimer claims the meeting was voluntary, while Lovasz alleges he was told he must meet with the Gold firm and was picked up at home by limousine and taken to the office. Contemporaneous memoranda of this meeting prepared by the Gold firm indicate that Lovasz launched into a disjointed diatribe against Feinberg and Kennard and confided that he had witnessed Feinberg's forgery. Lovasz claims that he told counsel he was willing to testify as to these events, that counsel advised him not to say anything about what he knew until he had had time to think about it, and