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RE: CSSS status update



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. 

Haytham Faraj 

Sent from my iPhone


On Aug 16, 2011, at 5:03 PM, "Kevin Duff" <kduff@rddlaw.net> wrote:

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

 

Hey Kevin,

Do we have a new discovery order. What is our status with respect to trial schedule. 

 

 

Thanks. 

Haytham Faraj 

Sent from my iPhone


On Jul 21, 2011, at 11:54 AM, "Kevin Duff" <kduff@rddlaw.net> wrote:

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

Sent from my iPad


On Jul 20, 2011, at 6:11 PM, "Kevin Duff" <kduff@rddlaw.net> wrote:

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

 

Kevin. 

I'm out of the country. I will not be there. I'm eager to hear the decision however. 

Haytham Faraj

Sent from my iPad


On Jul 19, 2011, at 8:04 PM, "Kevin Duff" <kduff@rddlaw.net> wrote:

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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