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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 Sent: Fri 09/09/2011 8:47 AM To: 'John Murray'; lisa@csss.net; slater@billslater.com Cc: 'Kevin Duff' Subject: RE: (Cynowa v. CSSS) Drafts of Answer & Motion to Dismiss re: certain counts... 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. |
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