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From: Haytham Faraj <haytham@puckettfaraj.com>
To: <btani@itaniautohandel.com>,
	<jeanchdid@hotmail.com>,
	<mgusa@live.com>,
	<dagher61@aol.com>,
	<mike_awkal@yahoo.com>,
	<bjautollc09@live.com>
Cc: <farajh@gmail.com>,
	"'Chadi Nassif'" <chadi.nassif@sallaumgroup.us>,
	"'Sadek Toufeily \(Sallaum Lines USA\)'" <Sadek.Toufeily@sallaumlines.com>,
	"'mariam'" <mariam@puckettfaraj.com>
Subject: OFAC Seized automobile law suit
Date: Wed, 21 Dec 2011 14:48:17 -0500
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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.