VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF NORFOLK ROY L. PERRY-BEY and RONADL M. GREEN vs. Docket No.: CL19-3928 (MJH) CITY OF NORFOLK, et al OBJECTION TO DEFENDANTS. COURT'S ORDER SUSTAINING MOTION TO QUASH COMES NOW Plaintiffs, Roy L. Perry-Bey, and Ronald M. Green, respectfully, object to Defendants and the Court’s findings and decree as follows: Plaintiffs questions seek factual testimony in dispute based on the witnesses public statements and writings, or communications in the media and Court, that waived attorney client privilege; these facts clearly before the Court. Privileged communications do not become discoverable simply because they are related to issues raised in the litigation." (Transamerica Title Ins. Co. v. Superior Court (1987) 188 Cal App. 3d 1047, 1052-1053.) 3. Attorneys acting as both a witness and advocate for the client must also consider the Rule of Professional Conduct Rule 3.7(a)'s prohibition on attorneys acting as an advocate in adversarial contested proceeding allowed in this case. 4. Defendants asserting an ‘advice of counsel’ defense generally constitutes a waiver of attorney client privilege.5. The Defendants wild-bald assertion the proffer was not presented to the City Attorney's office is frivolous. 6. The Defendants assertion that unethical or conflict of interests are not relevant to any claim, the Court should have rejected, because the Court is not obligated to consider legal conclusions, even if they are faulty or omitted. 7. The Plaintiffs have loss confidence in the Court safeguarding of their constitutional right to a fair or impartial forum Friday, May 31, 2019 Respectfully Submitted, PERRY-BEY 89 LINCOLN STREET #1772 HAMPTON, VA 23669 (804) 362.0011CERTIFICATION OF SERVICE I hereby certify that a true copy of the foregoing was mailed on this 31st day of May, 2019 to Adam D. Melita, Deputy City Attorney, City of Norfolk, City Hall Building, 9th Floor, 810 Union Street Norfolk, VA 23510. By. LES PERRY- BEY MR. ROY 89 LINCOLN STREET #1772 HAMPTON, VIRGINIA 23669