From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Gentlemen, I have contacted all of you regarding the matter of your blocked and seized vehicles. I have expended a lot of time and effort working on obtaining a license to unblock your vehicles without any success. We are now at a crossroads. You may continue to wait until OFAC and Customs and Border Protection decide to make a decision or we can sue the Department of Homeland Security and Department of Treasury to retrieve your vehicles and recoup your losses. I recommend filing the law suit. I recommend the filing of a law suit for a number of reasons. 1) They will know that you are serious about this matter and that you will not agree to continue waiting; 2) By filing a law suit you will get both agencies –OFAC and CBP- to move quickly on your petitions to unblock; 3) when I sue I will be asking for release of your vehicles and recovery of your losses which includes the value of depreciation of the vehicles, storage costs, value of lost opportunity, punitive damages and attorney fees. Some of you may be concerned about suing the U.S. Government. Let me assure that you have nothing to be concerned about. I am a former Military officer and have extensive experience dealing with Government agencies and their methods. I am also an experienced trial attorney thoroughly familiar with actions of this sort. Before I file I will need to address a couple of matters. 1. To minimize the costs to all of you, I intend to file a law suit naming all of you in the same law suit. That will substantially reduce your costs. Accordingly, I will need each of you to respond to this email agreeing to be part of the same law suit or declining to be a part of the law suit. If I do not receive a positive response, I will consider that a declination. If you decline you will not be named in the law suit. 2. If you agree to be a party to the law suit you will have to pay your own legal fees as Sallaum Lines is not funding the law suit. I expect the law suit to cost between $40,000 and $60,000. It will be $40, 000 if we settle the matter before trial which means they will release all your cars before we go to trial as part of a settlement. It will cost $60,000 if we have to go to trial. I propose dividing the cost of the law suit by the number of cars so that each one of you pays a portion based on the number of cars each of you has blocked. There are a total of 400 cars that are blocked. That comes out to $100 per car if we settle before going to trial and $150 per car if we have to go to trial. In the event we go to trial and win, we will also be entitled to whatever attorney fees the court awards us and 30% of punitive damages that we recover. We will not be entitled to take any portion of any actual or economic damages we recover on your behalf. If you agree to the terms I set forth in this email please respond email me back to let me know you agree. I will then send you each a retainer agreement which you will need to sign and send back to me with your initial retainer of $100 per car. Please send me any questions you may have. You may call me at my Dearborn office at 313-457-1390. Below I have provided a listing of the dealers and how many cars each of you has blocked. Before we file I will send you a detailed list of blocked cars and VIN numbers so you can verify. I will also request from you an approximate amount of how much this seizure action has cost you. Itani Auto Handel 16 automobiles Jean chedid 31 cars automobiles MG 11 automobiles Naya and Kamal El Khawand 54 automobiles Saab and Awkal 120 automobiles B and J 35 autombiles LMT 119 automobiles Ahmad Kassam 2 automobiles A and Z 10 automobiles I look forward to your responses. Best regards, 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 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |