Gary Goodwin is a partner in Steinway, Goodwin & Iverson. He represents Bill Smith, a defendant in a lawsuit filed by his brother, George Smith. The litigation has been very contentious. George is represented by Alex Philbin, who has a reputation for being a “junkyard dog” litigator. As part of the discovery process, the parties agreed to allow Philbin and a forensic accountant visit Bill’s office and review the original accounting records kept by Bill in a joint venture with George. Deena is a paralegal at Steinway, Goodwin & Iverson and working on the Smith case with Gary. On the morning of the visit to Bill’s office, the receptionist calls Deena and frantically explains that Mr. Philbin is on the phone and very angry. He is saying something about Bill Smith not letting him look at the documents. The receptionist explained that Gary is in a meeting, but Philbin is claiming Bill Smith is in breach of a discovery agreement. The receptionist wants Deena to take the call. In speaking to Mr. Philbin, what is the best approach for Deena to take?
