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HERBERT S. ROSENBLUM Attorney and Counselor at
Law A Professional Corporation Mailing Address: Post Office Box 58 Telephone:
703/684-0060 Facsimile:
703/684-0072 E-Mail: herbert@hsrlawpc.com February 18, 2011 SENT VIA EMAIL
@ Haytham@puckettfaraj.com SENT VIA
FACSIMILE @ 202/280-1039 Haytham Faraj, Esquire Puckett & Faraj, PC Re: MVM,
Inc.; 3D Global Solutions, Inc. vs. Case
No: 1:06cv00722 (GK) Our
File No. 4647/02 Dear Haytham: In
an attempt to resolve our ongoing litigation and to follow up on our clients’
meeting of several days ago, I propose that the matter be resolved as follows: 1.) For three years following the date of this
letter, if MVM responds to an RFP or an RFQ that contains a requirement for
services that MVM chooses to provide through a vendor or subcontractor, which
services are of the type 3D has advised MVM in writing that it is capable of
providing, MVM shall give 3D an opportunity to bid to provide such services. 2.) MVM will evaluate any such 3D bid as well as all
other bids to provide such services in good faith using criteria customarily
used by MVM to award such work to a vendor or subcontractor. 3.) MVM will appoint an employee, who will be
identified to 3D, who is and will be under an obligation to monitor MVM’s
good faith efforts to fully comply with the letter and spirit of this understanding.
4.) If 3D believes that MVM is not in compliance with
this understanding, 3D shall notify the MVM monitor and MVM and 3D shall meet immediately
to review 3D’s complaint and to remedy any non-compliance. 5.) Each company, for itself and its agents,
employees and officers, agrees not to interfere with the letter and spirit of this
understanding and agrees not to interfere in the valid business judgments and
decisions of each company. 6.) The pending civil action now pending in the
United States District Court for the Please call me on my cell phone at
(703) 967-4311 to discuss. Very
truly yours, /s/ Herbert
S. Rosenblum HSR/jcm Enclosures: as noted. Cc: Client JoAnne C. Moore Legal Assistant HERBERT S. ROSENBLUM Attorney and Counselor at
Law Telephone: 703/684-0060 Facsimile: 703/684-0072 |