Warren see below.Haytham FarajSent from my iPhone
Begin forwarded message:
From: "Hobbs, Michael D." <michael.hobbs@troutmansanders.com>
Date: December 21, 2011 9:33:54 AM EST
To: "Hobbs, Michael D." <michael.hobbs@troutmansanders.com>, 'Haytham Faraj' <haytham@puckettfaraj.com>
Cc: "McNutt, Steve" <Steven.McNutt@troutmansanders.com>, "'Abed A. Ayoub, Esq.'" <aayoub@adc.org>, "'malek@malekjandali.com'" <malek@malekjandali.com>
Subject: RE: Request for Extension of Time to File AnswerHaytham:
We are in receipt of your e-mail of December 20, 2011. Mr. Jandali made an offer of settlement back in September as set forth below.
Michael D. Hobbs, Jr.
TROUTMAN SANDERS LLP
600 Peachtree Street
Suite 5200
Atlanta, Georgia 30308-2216
(T) 404.885.3330
(F) 404.962.6588
michael.hobbs@troutmansanders.com
From: Hobbs, Michael D.
Sent: Wednesday, September 07, 2011 10:57 AM
To: 'Abed A. Ayoub, Esq.'
Cc: McNutt, Steve
Subject: RE: Request for Extension of Time to File Answer
Mr. Ayoub:
Thank you for your e-mail. I have spoken to Mr. Jandali and we are willing to consent to a 10 day extension of time. We believe that 10 days should provide able time to determine whether this matter will settle.
Responding to your e-mail of August 29, 2011, to settle the matter, we need the text of the apology to read as follows:
ADC Press Release
An Apology to Mr. Malek Jandali
The ADC would like to apologize to Mr. Malek Jandali, his fans and the Arab-American community for the unfortunate circumstances regarding the performance of his piece "Watani Ana" at the June 2011 ADC National Convention. We regret that Mr. Jandali's invitation to the event was withdrawn, and that his song "Watani Ana" was nevertheless played at the ADC annual Gala without his permission.
We are pleased to announce that ADC has reached an amicable resolution with Mr. Jandali regarding this matter. As part of our resolution with Mr. Jandali, ADC will make a contribution on his behalf to the International Federation of Red Cross and Red Crescent Societies. Mr. Jandali is a composer & pianist of the highest caliber. ADC will continue to support him and his powerful message of peace, freedom and harmony. It is in this spirit we hope to move forward and continue to build our grassroots network, as we work to empower Arab Americans.
Turning to the other settlement issues, to resolve this matter, ADC will need to make a payment to the Red Cross and Red Crescent Societies in the amount of $1000, and a payment to Mr. Jandali in the amount of $5000 to reimburse him for his court costs, service fees and legal charges incurred because the response of the ADC forced the filing of the current lawsuit.
These settlement terms are reasonable and not negotiable. If they are unacceptable to the ADC, please advise me and we will move forward with the litigation where Mr. Jandali will pursue all damages and legal remedies.
Michael D. Hobbs, Jr.
TROUTMAN SANDERS LLP
600 Peachtree Street
Suite 5200
Atlanta, Georgia 30308-2216
(T) 404.885.3330
(F) 404.962.6588
michael.hobbs@troutmansanders.com
From: abedayoub@gmail.com [mailto:abedayoub@gmail.com] On Behalf Of Abed A. Ayoub, Esq.
Sent: Wednesday, September 07, 2011 12:40 AM
To: Hobbs, Michael D.
Subject: Request for Extension of Time to File Answer
Mr. Hobbs,
I hope this message finds you well.
The purpose of this e-mail is to determine whether or not you object to a 30 day extension of time to answer the complaint. Currently the answer is due on September 8, 2011. I have prepared a Motion for Extension to file accordingly prior to Thursday. As you are aware ADC is the Nation's largest Arab-American Civil Rights organization, and given the upcoming 10 Anniversary of 9/11 the ADC Legal Department has been working to address an influx in discrimination complaints, and at the same time work with law enforcement and government agencies across the country to protect community members who may be victims of Anti-Arab backlash.
Your anticipated response is appreciated. Should you have any questions please feel free to call me at the office, 202-244-2990, or on my cell phone at 313-995-3333.
Thank you again,
Abed A. Ayoub
Abed A. Ayoub, Esq.
Legal Director
American-Arab Anti-Discrimination Committee (ADC)
1732 Wisconsin Ave., NW
Washington, DC 20007
Tel: 202-244-2990
Fax: 202-333-3980
This e-mail communication, including any attachments, may contain legally privileged and confidential information. This information is intended solely for the use of the intended recipient. If you are not the intended recipient, you should immediately stop reading this message and delete it from your system. Any unauthorized reading, distribution, copying or other use of this communication, or its attachments, is strictly prohibited.
IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice that may be contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction(s) or tax-related matter(s) that may be addressed herein.
This e-mail communication (including any attachments) may contain legally privileged and confidential information intended solely for the use of the intended recipient. If you are not the intended recipient, you should immediately stop reading this message and delete it from your system. Any unauthorized reading, distribution, copying or other use of this communication (or its attachments) is strictly prohibited.
1732 Wisconsin Ave., NW | Washington, DC 20007
Phone: 202.244.2990 ext.110 | Fax: 202.333.3980
This e-mail communication, including any attachments, may contain legally privileged and confidential information. This information is intended solely for the use of the intended recipient. If you are not the intended recipient, you should immediately stop reading this message and delete it from your system. Any unauthorized reading, distribution, copying or other use of this communication, or its attachments, is strictly prohibited.