Thanks for letting me know, Haytham. It sounds like we disagree on the facts. We will proceed accordingly.
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, June 21, 2011 12:53 PM
To: Chubin Epstein, Ellen (USADC)
Subject: RE: Ramon Davila
Hi Ellen,
Weâve considered the plea offer. Mr. Davila simply cannot plead guilty to any criminal misconduct as a result of any intentional misrepresentation. At worst,
he may have some benign errors in reporting. He cannot admit to ever reporting having met someone when he did not or any other material misrepresentation. I recognize that this email constitutes a rejection of your offer. I attempted to find a petty offense
that could encapsulate the facts as we know them to be in the hope that I can make a counter-offer. Unfortunately, I did not. This isnât about the exposure to punishment. It is about Mr. Davilaâs ability to stand in front of a judge and admit to things
that did not happen. We worked on developing the facts to try and find a compromise but could not fit the charges into the facts as we know them to be.
Best regards,
Haytham
From: Chubin Epstein, Ellen (USADC) [mailto:Ellen.Chubin@usdoj.gov]
Sent: Friday, June 03, 2011 2:25 PM
To: Haytham Faraj
Subject: RE: Ramon Davila
Thanks for letting me know, Haytham. Enjoy your weekend, too.
Ellen
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Friday, June 03, 2011 2:04 PM
To: Chubin Epstein, Ellen (USADC)
Subject: Re: Ramon Davila
My Michigan address has changed. My new address is: 22167 Morley Ave. Dearborn, MI 48124.
Haytham
Sent from my iPad
Hi, Haytham. I hope this email finds you well. Iâve been back from maternity leave for a few months now, and I have been turning my attention once
again to Mr. Davilaâs false representations in reports of background investigations.
Although you previously indicated that your client was not interested in a guilty plea, I wanted to let you know that the government is still willing
to resolve this matter prior to indictment, in order to avoid a potential trial and the associated expenditure of government resources.
Accordingly, I am attaching a pre-indictment plea offer, which will expire on June 17, 2011. In this plea offer, the government agrees to allocute for
a sentence just below the bottom of the applicable Guideline range. If this offer is rejected, any future plea deal will not be nearly as generous to your client.
Please feel free to call me if you have any questions.
Ellen
Ellen Chubin Epstein
Assistant U.S. Attorney for D.C.
Fraud & Public Corruption Section
555 Fourth Street, NW
Room 5255
Washington, DC 20530
(202) 252-7861 (office)
(202) 307-2304 (fax)
(202) 471-0670 (Blackberry)
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Monday, July 12, 2010 4:40 PM
To: Chubin Epstein, Ellen (USADC)
Subject: Ramon Davila
Dear Ms. Chubin-Epstein:
Mr. Davila has considered your offer of pleading guilty to charges of falsifying records or statements. He declines your offer.
Vr,
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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