Haytham: I attach a draft agreement between Sallaum and A+E. I have made Virginia law the governing law because our client is located in Virginia. I did not have data on A+E, such as whether A+E is a d/b/a or a c-corporation. It appears that Sallaum is a C-Corp, but can you confirm that? If either or both is just a d/b/a then I will need to list the owners as Parties to the Agreement. Mary Jo Provenzano Paralegal PUCKETT & FARAJ, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax 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. From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Hi Mary Jo, This is the task I spoke to you about on Monday. Sallaum Lines, our client, is in the automobile shipping business. One of their clients is A plus E Auto Exports. The owner of A plus E is Mr. Elie Huways (508-801-7239). Mr. Huways is very nice and easy to speak to. He, however, is a bit upset because Sallaum Lines’ former employee filled out dock receipts for 17 of Mr. Huway’s vehicles listing “Ellissa” as the consignee. Mr. Huways has never used “Ellissa” as a consignee. As you may know Ellissa is listed as a specially designated drug trafficker. Interestingly, when that information was inputted in CPB’s AES system, the correct consignee was listed. Because Ellissa was listed in the dock receipts, CBP seized all 17 vehicles. The seizure occurred in May of this year. I have been working with CBP to have them released but have thus far been unsuccessful. Their investigation continues. A couple of weeks ago, Sallaum Lines decided to purchase the seized vehicles from Mr. Huways in recognition of their error in listing the wrong consignee. They have paid Mr. Huways $100,000. The owe him another seventy or so thousand dollars. They asked us to draft a sales agreement that transfers the right of ownership to Sallaum Lines in all 17 vehicles. Remember that the vehicles remain with CBP so they will not get possession but they hope to. I also want you to draft a settlement agreement to ensure that A Plus E/ Huways gives up any claims or causes of action against Sallaum Lines. I am attaching my letter to CBP along with receipts provided by CBP upon seizure of the vehicles. I am also providing you two sample settlement agreements that you will be able to modify for your purposes. You will need the exact amount of the settlement. I will get that to you as soon as I can. 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 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. |
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AGREEMENT MUTUAL RELEASE - A+E.docx
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