RE: Jandali v. ADC Request for Admissions

Actually I think the Motion to Dismiss is even more appropriate.Â I am not sure if you want to file that right away or if you want some more discovery first.Â I am thinking Rule 11 coming after that.

Mary Jo Provenzano

Paralegal

PUCKETT & FARAJ, PC

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

202-280-1039 Fax

www.puckettfaraj.com

DC × CA × MI × VA

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From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, December 07, 2011 3:48 PM
To: MaryJo Provenzano
Cc: Neal Puckett
Subject: Re: Jandali v. ADC Request for Admissions

Well done. I think your assessment of the Rule 11 motion is dead on. I have also contemplated a motion to dismiss from the get go as you know. Perhaps we can still do it.

Haytham Faraj

Sent from my iPhone

On Dec 7, 2011, at 3:36 PM, "MaryJo Provenzano" <maryjo1@puckettfaraj.com> wrote:

Haytham:

I updated the RFAâs a little, but we already had a request for him to admit that he had knowledge about the embedded YouTube post. I just tweaked it a little. I also added Request 19 that references the page from Facebook where he admits to knowing about the proposed broadcast of the YouTube post prior to the Convention, assuming that we can get Mr. Ayoub to get it to us.

I am also wondering if we might have a Rule 11 claim here. This is clearly a frivolous lawsuit that Mr. Jandali filed to âpunishâ the ADC. He has misrepresented the facts about being disinvited and being censored by the ADC (I think this is what is in the Facebook page, judging from the backlash I found on the social media from his fansâ blogs â see attached.) His attorneys knew or should have known that there was no claim upon which relief could be granted, unless their client lied to them too. Iâm not saying we should raise Rule 11 yet, but it may be something you may want to consider after discovery.

On the âbacklashâ, my favorite blog is the first that I scanned into this file â note he has the YouTube post embedded into his blog. I also attached the ADC press releases just before the Convention that I found.

Mary Jo Provenzano
Paralegal

PUCKETT & FARAJ, PC
1800 Diagonal Road
Suite 210
Alexandria, VA 22314
703-706-0442 Phone
202-280-1039 Fax

www.puckettfaraj.com
DC × CA × MI × VA
twitter.com/puckettfaraj

Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender.

<ADC ads Jandali. Requests for Admission TO PLAINTIFF.docx>

<adc facebook backlash.pdf>

<adc press releases.pdf>