Following is the message that I left on your answering machine on April,    2004, over six months since the last word I spoke or wrote to you. In this message, I beg you to avoid the need for a lawsuit, and warn you that your lawyers at Beldock, Levine and Hoffman have been misadvising you, can no longer defend you, and will be held to account. Had you called me, you would have learned that your lawyers and manager had lied to you about the reason Rounder threatened to cancel your contract, and you would have been told that the letter explaining the reason for my lawsuit against you had been withheld by your Lawyer Jeffrey Greenberg.

Instead of responding in the spirit of my message, you took the message to your lawyer Myron Beldock, who recorded the message off your cell phone and suggested that you take it to the Police in order to initiate a restraining order against me. You describe the circumstances in your deposition.

TRANSCRIPT OF MY APRIL, 2004 PHONE MESSAGE TO YOU

[Mr. Beldock's vioice]: "Beldock dictating testing one two three four It's april 12th. We're attempting to record a message from Mr. Galison which is on Ms. Peyroux's cell phone":

[machine voice] "Saved message monday, two-o-six pm."

[William Galison's] voice:  "Hi Madi, its William. Listen, I spoke to Danny the other day and  uh, I realize that uh I think that you've missed, that you might have perhaps been misadvised for a long time about what's going on legally. Um, You're going to be served papers soon; later this week, and its something I had to do because um, I have to defend my reputation and my career. And I just want you to know that I don't hate you-  that I'm really am concerned about you, and that I'm concerned about me,  and uh,  I think its its going to get quite serious legally  Uh, Jeff Greenberg's gotten himself in big trouble as far as I understand  with the New York Bar Association and he won't be able to defend you, as far as I understand.  and um I don't want your life to be badly affected by this but I had to do this because my life is being badly affected. Um,  so I'm really sorry that its come to this.

If you ever want to talk to me about it you can call me.. ...I still have a lot of fond feelings for you we’ve been through a lot of things together,  we helped ourselves, each other through a lot of things. So I hope you'll call me. I don't think your friends have served you well, I don't think your Mom has served you well and i don't think Danny and all the other people who have given you advice and uh I'm not looking forward to seeing this thing go on. but it has to now, its in the hands of the federal court I miss you a lot and I wish this whole thing wasn't happening.

YOUR DEPOSITION REGARDING THE APRIL PHONE MESSAGE

A    And while I was out of the state, I didn't pursue it at all. When I came back to New York, I received -- and when I came back to New York, it was actually April of the following year.  So some time had passed.  I received another phone  call from William Galison.  And based on that, I tried to make a -- file a complaint, but --

Q    Well, tell me about that. When did you -- with whom did you try to file a complaint?

A    I tried to file a complaint with the police department somewhere here in the City of New York downtown.

Q    You mean at a precinct house?

A    Yes.

Q    Do you remember which precinct it was?

A    I believe it was way  downtown, near the VA, something like  that.

Q    You mean downtown like as far as downtown like where my office  is?

A    Some -- something like that.  It would have been near the VA hospital, I think.

Q    I don't know where it is. But I only know the one out in Brooklyn and near the Verrazano Bridge.  Okay.  I didn't mean to  interrupt you.  So you went to a police precinct, and what did you do there?

A    I tried to file a complaint.

Q    Okay.  And what did you say  had happened?

A    I said that I had received this phone call, and I would like  to -- because I was anticipating that  I would be getting more phone calls. So I said I would like  to -- I wanted to pursue having a restraining order, but that takes a long time.  And he was calling other people in my life.  Apparently the situation is that -- or I was told that--

Q    Can I interrupt you?  And you've been so good, but could I just  interrupt you and say, what was the  phone call that you received from him  in April of 2004 that sent you to the police?

A    It was a phone call from William Galison.  But the content was something to the effect of I love you, but I'm filing a lawsuit against you this week or something like that. It may be that he asked me to contact him.  And I don't remember the rest of it.

   Q    Okay.  Were there any  threats in it, physical violence or  harm to you?

A    No, there were no threats  in it.

Q    Do you have documentation  of that call?  Is that the call you  transcribed?

A    Yes.

MR. RUSSELL:  Okay.  I'd  call for the production of that, and we'll put it in a more  formal request after the  deposition is over and we'll   reserve the right to ask questions about it thereafter.