Warren,
I gave Laila my contact info. Let's chat in the morning for a few minutes.
Thanks,
Abed Great! See you then... On Sun, Nov 6, 2011 at 4:29 PM, Haytham Faraj <haytham@puckettfaraj.com> wrote:
After 330 is perfect. I have to be in court from 130 to about 230. I can come to the office after I finish in court. I can be there by 330.
See you tomorrow.
Haytham Faraj Sent from my iPhoneHi Haytham, let's talk tomorrow. I an open after 3:30 pm. Do you want to cone to ADC? Let me know your availability.
Warren
Warren David
ADC President 1732 Wisconsin Ave. NW Washington, D.C. 20007
Sent from my iPhone
Warren,
Hope things are going well. Please see the message below from Haytham regarding the Jandali case. Haytham believes there is still room for settlement, but needs to know his parameters and what he can work with. Given the time restraints could you please meet with Haytham on Monday afternoon at our office to discuss the parameters of such a settlement.
Haytham -- I won't be back until Wed. I am available via email, or Skype. If the meeting is anytime before 1:30 tomorrow you can FaceTime or Skype me in.
Thanks,
Begin forwarded message:
----- Forwarded message from haytham@puckettfaraj.com -----
Date: Sat, 5 Nov 2011 11:09:16 -0400 From: Haytham Faraj <haytham@puckettfaraj.com>
Reply-To: Haytham Faraj <haytham@puckettfaraj.com> Subject: Proposed request for admission
To: "'Abed A. Ayoub, Esq.'" <aayoub@adc.org>Abed,
Counsel for Jandali and I held a Rule 26 conference On Oct 31, to discuss
discovery, scheduling and the preparation of a scheduling conferencestatement. My approach was non-adversarial to keep doors open for apossible settlement and pitched the Turrath event. They declined the
Turrath event unless it also incorporated some of his settlement terms fromthe first offer. I think there may still be an opportunity to settle but Ineed to sit with you to understand the parameters that I am allowed to work
within. I am available Monday afternoon and can come to your office if youare going to be back. I am also available Tuesday but you will have to cometo my office in Alexandria.
I am attaching our draft first request for admissions. I have not createdinterrogatories or noticed a deposition yet because I do not want to engage
in full combat to see if we can settle this as quickly as possible. Pleasereview and make recommendations to the request for admissions. I intend toreengage them on settlement talks again this month. If I see that he is
being inflexible, I will then notice a deposition and begin to engage inmore targeted discovery.I hope you're enjoying your trip and I look forward to seeing you.
Best,Haytham Faraj, Esq.PUCKETT & FARAJ, PC
_______________________WASHINGTON DC METROThe Law Firm of Puckett & Faraj, PC1800 Diagonal Road
Suite 210Alexandria, VA 22314703-706-0442 Phone202-280-1039 Fax
DETROIT METROThe Law Firm of Puckett & Faraj, PC835 Mason StreetSuite 150-ADearborn, MI 48124
313-457-1390 Phone202-280-1039 Fax
<http://www.puckettfaraj.com/> www.puckettfaraj.com
The information contained in this electronic message is confidential, and isintended 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 anyuse, distribution, copying of disclosure of this communication is strictlyprohibited. 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.
----- End forwarded message -----
Abed, Counsel for Jandali and I held a Rule 26 conference On Oct 31, to discuss discovery, scheduling and the preparation of a scheduling conference statement. My approach was non-adversarial to keep doors open for a possible settlement and pitched the Turrath event. They declined the Turrath event unless it also incorporated some of his settlement terms from the first offer. I think there may still be an opportunity to settle but I need to sit with you to understand the parameters that I am allowed to work within. I am available Monday afternoon and can come to your office if you are going to be back. I am also available Tuesday but you will have to come to my office in Alexandria.
I am attaching our draft first request for admissions. I have not created interrogatories or noticed a deposition yet because I do not want to engage in full combat to see if we can settle this as quickly as possible. Please review and make recommendations to the request for admissions. I intend to reengage them on settlement talks again this month. If I see that he is being inflexible, I will then notice a deposition and begin to engage in more targeted discovery.
I hope youâre enjoying your trip and I look forward to seeing you. Best,
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
www.puckettfaraj.com
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.
<ADC ads Jandali Requests for Admission TO PLAINTIFF.pdf>
--
Warren David
ADC President
American-Arab Anti-Discrimination Committee (ADC)1732 Wisconsin Ave., NW | Washington, DC 20007
Phone: 202.244.2990 ext.110 | Fax: 202.333.3980
wdavid@adc.org | www.adc.org 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.
|