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RE: CSSS law suit



Haytham: I am resending the cover sheet and complaint. Do you need anything else? Mary Jo

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, January 18, 2012 12:47 PM
To: MaryJo Provenzano
Subject: Re: CSSS law suit

 

Neal is not licensed in DC. You'll have to use mine. If you send me everything I'll review and file tonight. 

Haytham Faraj 

Sent from my iPhone


On Jan 18, 2012, at 9:02 AM, "MaryJo Provenzano" <maryjo1@puckettfaraj.com> wrote:

Hi Haytham.

Thanks for your understanding.  I am feeling a whole lot better today.  I have revised some of the facts as well as the client name on the Complaint (I added more to the legislative history in the first few paragraphs of the facts.  I also added that CSSS is a Subchapter S corporation because I think it's relevant.)

I have completed a new cover sheet as well. 

 

I don't think I can file this without some method of paying the filing fee.  Can you help out with that or would you rather file this your self?

 

Finally, I have the following ECF code from Neal:  Login:   puckett699

PW:      iu77iu84

Do you have a different code or do I just use this one?

 

Thanks.

 

Mary Jo

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, January 17, 2012 3:12 PM
To: MaryJo Provenzano
Subject: Re: CSSS law suit

 

Understand all. Let's chat tomorrow. Hopefully you'll be feeling a little better. 

Haytham Faraj 

Sent from my iPhone


On Jan 17, 2012, at 10:31 AM, "MaryJo Provenzano" <maryjo1@puckettfaraj.com> wrote:

Haytham:  I have a few questions: 

1. I have attached the Complaint with the client's changes accepted, but please note:  I deleted trial by jury since a determination on an injunction is a matter of law.  That's why I had Trial by Jury in brackets on my last draft.  Also, I wanted to search some more to see if there was a "property right" Constitutional argument to be made.  I think it would be under the Fifth Amendment since the 14th and 42 USC 1983 only apply to state action.  If you are comfortable that we can file an amended  complaint (assuming I find a ground for suit), then I'm ok with filing now.  Otherwise, I'd like just a little more time with this.  I got your DC Bar # from Mariam and signed Complaint and Cover Sheet so I could attach the PDFs.  It's been a while since I filed a Federal Complaint, but I am guessing that when you sign in to file it on the ECF you give it a credit card for the filing and service fees?

 

2.  You can't serve the Motion for Prelim Injunction till you serve the complaint. I understand that you want me to make any requested changes to the Memo and for filing at the appropriate time.

 

3.  I am really trying to recover from a nasty case of stomach flu that I got on Sunday.  I will only be here till 2:00 EST because I'm kind of having trouble focusing. Since we can't file it at this point anyway, I did not send you the Motion for Prelim Injunction because I have not reviewed it yet. I wanted to wait on that till I can think straight, which will hopefully be tomorrow. I hope this is ok.

 

Mary Jo

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, January 17, 2012 10:29 AM
To: 'MaryJo Provenzano'
Subject: CSSS law suit

 

Mary Jo,

I am attaching the Complaint and injunction for CSSS.  Please correct the heading to reflect the actual name of the company.  Please prepare the civil cover sheet and get this ready for filing.  I would like it filed today if possible so as soon as you finish everything, email me the PDF documents so I can review and file.

 

Thank you

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

The Law Firm of Puckett & Faraj, PC

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

202-280-1039 Fax

 

DETROIT METRO

The Law Firm of Puckett & Faraj, PC

835 Mason Street

Suite 150-A

Dearborn, MI 48124

313-457-1390 Phone

202-280-1039 Fax

 

 

www.puckettfaraj.com

 

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<csss.net cover sheet .pdf>

<csss complaint.pdf>


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Checked by AVG - www.avg.com
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<CSSS.NET civil cover sheet.pdf>

<CSSS.NET COMPLAINT 1-18-12.pdf>


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Attachment: CSSS.NET civil cover sheet.pdf
Description: Adobe PDF document

Attachment: CSSS.NET COMPLAINT 1-18-12.pdf
Description: Adobe PDF document