Sounds good. I should be available any
time after 10. Give me a heads up to know when to expect you.
From: Haytham Faraj
[mailto:haytham@puckettfaraj.com]
Sent: Tuesday, August 16, 2011
4:13 PM
To: Kevin Duff
Subject: CSSS status update
I'll actually be there
tomorrow. Flying from DC in 30 minutes. I'm available in the morning if you
want to get together.
Sent from my iPhone
Hi Haytham,
The is no trial date set. Our
response to the second amended complaint is due September 9. There is a
status hearing date on September 20. No other dates have been set at this
time. We are preparing a motion to dismiss some of the claims of the
second amended complaint and likely will recommend answering certain
others. We will communicated with you and provide you papers for your
review and comment in advance of dates due to get your input and
comments.
Next time you will be in Chicago,
let’s get together. Please let me know your schedule.
Regards,
Kevin
From: Haytham Faraj
[mailto:haytham@puckettfaraj.com]
Sent: Tuesday, August 16, 2011
3:57 PM
To: Kevin Duff
Subject: Re: tomorrow's hearing
Do we have a new discovery order. What is our status with respect to
trial schedule.
Thanks.
Sent from my iPhone
Agreed
From: Haytham Faraj
[mailto:haytham@puckettfaraj.com]
Sent: Thursday, July 21, 2011 1:15
AM
To: Kevin
Duff
Cc: <jmurray@rddlaw.net>;
<mhughes@rddlaw.net>
Subject: Re: tomorrow's hearing
I'm not really surprised. If this judge were going to make Theresa
follow the rules, she would have done so long ago.
Haytham Faraj
Haytham,
Not surprisingly, the Court granted the
motion for leave to amend. We’ll send you a copy of the order.
During the hearing, Theresa Johnson made
numerous admissions about their lack of evidence that may be helpful as we go
forward.
Regards,
Kevin
From: Haytham Faraj
[mailto:haytham@puckettfaraj.com]
Sent: Wednesday, July 20, 2011
2:46 AM
To: Kevin
Duff
Subject: Re: tomorrow's hearing
I'm out of the country. I will not be there. I'm eager to hear the
decision however.
Haytham Faraj
Haytham,
Are you planning to be at the hearing
tomorrow?
Kevin
Kevin B. Duff
Rachlis Durham Duff Adler & Peel, LLC
542 South Dearborn Street, Suite 900
Chicago,
Illinois
60605
phone: 312-733-3390
fax: 312-733-3952
mobile: 312-218-8620
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