RE: FW: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

["Kevin Duff" <kduff@rddlaw.net>]

Bill,

The damages amount in the new pleading is just to show the can meet the
jurisdictional minimum to be in this court.  The damages the seek has not
changed.  Also, the $825K figure was a settlement demand.  If this gets to
trial they will ask for more, but that is not the point of this current
motion.  Thanks for your additional thoughts on this.

Kevin

-----Original Message-----
From: William Favre Slater III [mailto:slater@billslater.com] 
Sent: Friday, April 08, 2011 9:15 AM
To: Kevin Duff
Cc: lisa@csss.net; slater@billslater.com; jmurray@rddlaw.net;
kpritchard@rddlaw.net; 'Haytham'
Subject: Re: FW: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt
& proposed Second Amd Complt

Thanks, Kevin.

Hey - looks like that damages amount thing is moving in the right
direction, down from the $825K they last asked for.

Also, im my opinion, statements by Nikiforis and Engreji should be seen
exactly for what they are: cronyism and mobbing behavior.

Additional Facts:
Nikiforis has memory problems because of his medical condition.
Engreji is barred from testifying by the VA.
BOTH of these guys are so tight with Cynowa, that they would corroborate
ANYTHING Cynowa and Johnson asked.

Contact me if you need to brainstorm to address this new situation.

Best regards,


William F. Slater, III, PMP
Chicago, IL
United States of America
slater@billslater.com
http://billslater.com
http://billslater.com/career
773 - 235 - 3080 - Home
312 - 758 - 0307 - Mobile




> Lisa and Bill,
>
>
>
> Attached is Cynowa's motion for leave to amend his complaint along with
> the
> proposed second amended complaint.  Our response to the motion is due May
> 5.
>
>
>
> Kevin
>
>
>
>   _____
>
> From: THERESA JOHNSON [mailto:theresavjohnson@prodigy.net]
> Sent: Thursday, April 07, 2011 6:40 PM
> To: Kevin Duff
> Cc: John Murray; Haytham Faraj
> Subject: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt &
> proposed Second Amd Complt
>
>
>
>
>
>
>
>
>
>
>
> All,
>
> Attached please find Plaintiff's Motion for Leave to File Second Amended
> Verified Complaint and proposed Second Amended Verified Complaint file
> today, April 7, 2011.
>
>
>
> Sincerely,
>
> Theresa V. Johnson
> Attorney at Law
> Law Office of Theresa V. Johnson
> 200 East Chicago Ave. Suite 200
> Westmont, IL 60559
> Tel.: (630) 321-1330
> Fax: (630) 321-1185
>
>
>
>
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