agree. rejected.
Mike Dodd
One Source. Global Solutions.
CEO
1185 Ave of the Americas, Suite 1750
New York, New York 10036
Mike.Dodd@3dglobalsolutions.net
Toll free (866) 238-6761 ext 111
Direct Dial 212-205-6171
Fax 866-238-6761
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From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Saturday, February 19, 2011 10:01 AM
To: Michael Dodd
Subject: FW: MVM, Inc.; 3D Global Solutions, Inc. vs.
FYI. This is laughable.
From: JoAnne Moore [mailto:JoAnne@hsrlawpc.com]
Sent: Friday, February 18, 2011 2:30 PM
To: Haytham@puckettfaraj.com
Cc: Herbert Rosenblum
Subject: MVM, Inc.; 3D Global Solutions, Inc. vs.
HERBERT S. ROSENBLUM
Attorney and Counselor at Law
A Professional Corporation
526 King Street, Suite 211
Alexandria, Virginia 22314
Mailing Address:
Post Office Box 58
Alexandria, Virginia 22313-0058
Telephone: 703/684-0060
Facsimile: 703/684-0072
E-Mail: herbert@hsrlawpc.com
February 18, 2011
SENT VIA EMAIL @ Haytham@puckettfaraj.com
SENT VIA FACSIMILE @ 202/280-1039
Haytham Faraj, Esquire
Puckett & Faraj, PC
1800 Diagonal Road
Suite 210
Alexandria, Virginia 22314
Re: MVM, Inc.; 3D Global Solutions, Inc. vs.
Case No: 1:06cv00722 (GK)
Our File No. 4647/02
Dear Haytham:
In an attempt to resolve our ongoing litigation and to follow up on our clients’ meeting of several days ago, I propose that the matter be resolved as follows:
1.) For three years following the date of this letter, if MVM responds to an RFP or an RFQ that contains a requirement for services that MVM chooses to provide through a vendor or subcontractor, which services are of the type 3D has advised MVM in writing that it is capable of providing, MVM shall give 3D an opportunity to bid to provide such services.
2.) MVM will evaluate any such 3D bid as well as all other bids to provide such services in good faith using criteria customarily used by MVM to award such work to a vendor or subcontractor.
3.) MVM will appoint an employee, who will be identified to 3D, who is and will be under an obligation to monitor MVM’s good faith efforts to fully comply with the letter and spirit of this understanding.
4.) If 3D believes that MVM is not in compliance with this understanding, 3D shall notify the MVM monitor and MVM and 3D shall meet immediately to review 3D’s complaint and to remedy any non-compliance.
5.) Each company, for itself and its agents, employees and officers, agrees not to interfere with the letter and spirit of this understanding and agrees not to interfere in the valid business judgments and decisions of each company.
6.) The pending civil action now pending in the United States District Court for the District of Columbia between the parties shall be dismissed with prejudice.
Please call me on my cell phone at (703) 967-4311 to discuss.
Very truly yours,
/s/
Herbert S. Rosenblum
HSR/jcm
Enclosures: as noted.
Cc: Client
JoAnne C. Moore
Legal Assistant
HERBERT S. ROSENBLUM
Attorney and Counselor at Law
526 King Street, Suite 211
Alexandria , Virginia 22314
Telephone: 703/684-0060
Facsimile: 703/684-0072
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