| Agree. We need to set this probably before the 27 June hearing date. Problem will be Jones's schedule in Okinawa. Doubt he'll have an opening before then to go TAD to Pendleton. They've got a full docket. They're talking about setting one of my cases for mid-late Aug. Remember that if he denies our motions, NMCCA will be compelled to take the ex writ and we'll be back on hold again anyway, even if Jones has other ideas about pushing the case. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Apr 4, 2011, at 4:49 PM, Haytham Faraj wrote: We need to discuss timing. Jones will try everything in his power to push this motion to go immediately before trial. We need to get this on the docket ASAP. We need to have this heard by no later than early May. From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Monday, April 04, 2011 4:39 PM To: Haytham Faraj Subject: Re: Mariam Perfect! Misunderstanding all around and no harm intended or perceived. Closed matter. Let's make some money! BTW, Kaza volunteered to help draft a new motion for us. I say we let him help. They're all invested in this case. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Apr 4, 2011, at 4:19 PM, Haytham Faraj wrote: I take responsibility for the failure to communicate. I, like you, am always thinking of our ability to keep up with our financial obligations. I wasn’t planning to hire anyone in addition to her. I’ll explore the hourly and let you know. From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Monday, April 04, 2011 1:02 PM To: Haytham Faraj Subject: Re: Mariam Partner, Had no idea she was doing much of any work at all. That's why I recommended we cut her loose, and you told me you were thinking of doing that anyway, and perhaps substituting someone else on an hourly basis. Thought we were in agreement. This is why we need to talk more. My sense was that she was sort of a nice-to-have-available, "Girl Friday," and that she was rarely used. Hence the follow-up reminder email on Friday, in accordance with your agreement with me that she should go. You said you wanted to give her 30 days notice. If you've changed your mind since then, we can keep her on the payroll. But I still recommend she be paid according to the hours she actually works. Didn't know we had any disagreement about this, but you had never shared with me that she was actually doing any meaningful work. So last week when you said she lacked initiative and you were thinking of replacing her, I thought we were in 100% agreement. I stand better informed now. No worries! It's your call. Hourly or salary. Whichever you think is best for us. Just let me know so that I can adjust payroll. Probably shouldn't be bringing anyone else aboard, though, unless you decide to let her go. I work really hard to make sure there's enough money in the operating account to make payroll and pay our bills. Just give me a call if you'd like to discuss it further. Thanks for staying on top of the Donaldson account. N Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Apr 4, 2011, at 12:01 PM, Haytham Faraj wrote: Hey partner, I was disturbed by your email last week and a little upset by it. I wanted to wait to respond so as to provide an unemotional and cogent response. You caught me off guard in the office when you brought up that mariam needs to go and the reasons why. I was already thinking of replacing her because I have a better idea of what skills the next person needs to have but it is not because she is not doing what I task her with. Mariam has accomplished, and learned to accomplish, a variety of tasks including preparing case files for court, preparing correspondence, and organizing my trial binders. She organized and prepared the case file for the Hamama case which had a cumbersome amount of documents that had to be organized and cross referenced. She also prepared the budget expense spreadsheets for court and helped me track witnesses and expenses. She prepared my case file and witness folders for the Wacker and Card case, both of which have numerous witnesses that also must be organized and cross referenced. She prepared the witness request for Card’s Article 32 hearing with summaries of potential testimony of all the witnesses that is 11 pages long. She interviewed witnesses in Wofford’s case and prepared summaries of their testimonies. These are only a few of the matters she assisted with this year. Last year she assisted in the Vega, Brito, Wylde, and Scarselli cases also by preparing witness summaries for me and organizing and cross referencing witness statements. Given her tiny salary and the return I get, I consider her good value. I share all this with you so you can understand that she is not sitting around doing nothing. Though there are times when she is underutilized, it is not of her own doing. When she is idle, it is because we have no office to work in so she can’t access the files because they are at my house. I recognize that Bethany is supposed to help with some of these matters but a turnover at this time is not practicable unless I do it all. Mariam is currently preparing witness summaries of the Smith and Lopez investigations as well as continuing to work on the Card file. I hate to put this in an email I wanted to share my thoughts here so you know how I feel about this before we discuss it. I am available this afternoon after 1600 to discuss. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC P.O. Box 1016 Dearborn Heights, MI 48127 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |