Privileged & Confidential
Attorney Work Product
Draft
Task 2a: Model Interview Outline
Interview Outline – Jennifer Wong
[Date]
Note: The questions regarding the July 23, 2018 meeting would be inserted into an
outline that would cover other topics, including, among other things, the objectives of the
interview, a reminder that we represent Mr. Bradley and are not her counsel, Ms. Wong’s
background, employment history, her roles and responsibilities at Bradley & Co, as well as her
knowledge regarding any of the client portfolios at issue and communications with Mr. Bradley
regarding those portfolios.
I. JULY 23, 2018 MEETING
A. TAB [A]: J. Wong notes, dated July 23, 2018, reflecting a meeting with J.
Bradley and O. Fritz
1. Background
a. Who is O. Fritz? What is his role at Bradley & Co.?
b. Do you recall the context of this meeting? What was it?
c. Was it a regularly scheduled meeting? If not, who requested the
meeting?
d. Why were you included in the meeting?
2. “JB: Lots of questions from investors recently regarding progress of
investment and rates of return”
a. Did Bradley and Fritz discuss which investors were asking
questions? If yes, which ones?
b. Do you recall specifically what the investors were concerned
about?
3. “OF: Latest batch of reports sent June 28”
a. Do you recall what types of reports Fritz is referring to here?
b. Who sent the reports?
c. Who were they sent to?
d. Are these types of reports sent frequently? How frequently?
e. What types of information do these reports contain?
4. “JB: Next report – more specific. Need to limit questions from investors –
can handle some questions for now – risky.”
a. Do you recall why Bradley thought the report should be more
specific?
b. What specific details did Bradley want to include?
c. What does “risky” refer to? Do you recall why Bradley thought that
was risky?
d. Why did Bradley want to limit questions from investors?
5. “JB: Clients are questioning portfolio – can we generate report?”
a. Do you recall what clients were questioning the portfolio? Why?
b. What type of report is Bradley referring to here?
(1) Determine more information about report, including if a
standard report, special report, and the type of information
it would contain.
c. Do you recall if the report was generated?
(1) If yes, who was it provided to? By whom?
6. “JB: Progress on ensuring account statements align with report?”
a. Do you recall what Bradley is referring to in this statement?
b. What account statements is Bradley referring to?
(1) What information is included in the account statements?
(2) Who prepares them?
(3) How frequently are they sent?
c. What information from the account statements needed to align
with the report? Why?
7. “OF: Gerald progressing. Software designed to backdate – can ensure
matches reports.”
a. Who does Gerald refer to?
b. What is the reference to “software designed to backdate?”
(1) Depending on answer, follow up to determine name, who
used the software, and how it worked.
c. What needed to be backdated?
d. Why did that need to match reports?
8. “JB: Check dates”
a. Do you recall what Bradley was referring to?
b. What dates needed to be checked? Who was supposed to check
them?
9. “OF: Beech asked about outstanding return from May 2018”
a. Who does Beech refer to?
b. What was the outstanding return from May 2018?
10. “JB: Check new investors – transfer.”
a. Do you recall what Bradley was referring to in this statement?
11. “JB: Schedule weekly meeting – would like regular check-ins now that
getting more questions.”
a. Do you recall why Bradley wanted to schedule a weekly meeting?
b. Do you recall who these weekly meetings would include?
c. Did the suggested weekly meeting subsequently occur?
(1) If yes: when, for how long, who attended?
12. Is there anything else you recall about the July 23, 2018 meeting that we
haven’t discussed?