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Ok then sounds good…we’ll go with only absolute privilege
then. Thanks. John E. Murray, Esq. Associate Attorney Rachlis Durham Duff Adler &
Peel, LLC Phone: (312) 275-0338 Fax: (312) 733-3952 Email: jmurray@rddlaw.net Website: http://www.rddlaw.net RACHLIS This transmission may be: (1) subject to the Attorney-Client
Privilege, (2) an attorney work product, or (3) strictly confidential. If
you are not the intended recipient of this message, you may not disclose,
print, copy or disseminate this information. If you have received this in
error, please reply and notify the sender (only) and delete the message.
Unauthorized interception of this e-mail is a violation of federal criminal law. From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] I agree with your
analysis on absolute versus qualified privilege. I thought that reading
it but then thought it’s already in there anyway. I think your
analysis is on the mark. If we can’t win it on absolute then
we’re not likely to win it on qualified at this stage. I concur. From: Kevin Duff
[mailto:kduff@rddlaw.net] Lisa, Your recollection is correct that there
was an incident with the neighbors. I covered it with him at his
deposition. We were never able to locate a police report or the neighbors
despite repeated efforts. See the email I just sent. Regards, Kevin From: Wolford Lisa
[mailto:lisa@csss.net] I concur that if you look at Cynowa's
character there are bound to be lots of things. Probably in need of a
diagnosis... There was an issue that Darnella found where in
interviewing one of his crazy ex girlfriends that he fired a weapon or
threatened some neighbors while at a friends house. there was
definitely a weapon involved. The neighbors who were threatened did not
file charges but the ex girlfriend felt it was racial (the neighbors are
black) if I remember things correctly. However, I think that leopards
don't change their spots so there is likely to be other crazy/bizarre stuff in
his background. How do we find that out and how do we use that in
this case? I deliberately removed Bill off the email trail. I
didn't want any more "mobbing" emails... (smile). Thanks Lisa N. Wolford CSSS.NET 402-393-8059w 402-393-1825f SDVOB, 8(a)/SDB & WOB - TS clearances From: Haytham
Faraj Gentlemen, I’ve reviewed
the Answer to the 2nd amended Complaint and the Motion to
Dismiss. I have no recommendation or additions as to substance.
There are a few grammatical errors that I am sure will be picked up in the
final edit. Every time I dig
into this case I start to think about Cynowa’s character. Was there
any follow up with any of his ex wives and the young girl who got a restraining
order against him. And what about his ex boss at Orbitz and the real
reason he was terminated from there? Pardon me for digressing but I
thought about these matters after rereading the complaint. Best, Haytham From: John Murray
[mailto:jmurray@rddlaw.net] All: Attached please find a draft of our Answer to Plaintiff’s Second
Amended Complaint as well as a draft of our motion to dismiss certain counts,
which we will file on Friday. Please review the drafts and we’re
happy to hear your comments and/or concerns. Ideally we’d
appreciate any comments on the draft by tomorrow (Thursday) evening. We
will also be getting in touch with Lisa and Bill (either tomorrow or at the
latest Friday morning) to get your signed verification for the answer we
file. Thanks. Regards, John E. Murray, Esq. Associate Attorney Rachlis Durham Duff Adler &
Peel, LLC Phone: (312) 275-0338 Fax: (312) 733-3952 Email: jmurray@rddlaw.net Website: http://www.rddlaw.net/ RACHLIS This transmission may be: (1) subject to the Attorney-Client
Privilege, (2) an attorney work product, or (3) strictly confidential. If
you are not the intended recipient of this message, you may not disclose,
print, copy or disseminate this information. If you have received this in
error, please reply and notify the sender (only) and delete the message.
Unauthorized interception of this e-mail is a violation of federal criminal
law. |