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RE: (Cynowa v. CSSS) Larry Carver Motion



Understood.  Thanks.

 

Haytham, let’s chat about this when you have a moment.

 


From: Wolford Lisa [mailto:lisa@csss.net]
Sent: Wednesday, January 19, 2011 10:29 AM
To: Kevin Duff
Cc: Kathy Pritchard; John Murray; slater@billslater.com; haytham@puckettfaraj.com
Subject: RE: (Cynowa v. CSSS) Larry Carver Motion

 

Okay, I am good with going forward with his deposition now, that wasn’t the issue.  What I saw was we were bringing up his trying to steal a contract from CSSS in the motion and I don’t recall that from Darnella’s  deposition with Larry.  So that is what I meant by showing our hand.

 

Lisa N. Wolford

CSSS.NET

President & CEO

SDVOSB, 8(a)/SDB & WOB

202-639-5101 DC Office

402-393-8059 ext 145

 

From: Kevin Duff [mailto:kduff@rddlaw.net]
Sent: Wednesday, January 19, 2011 11:08 AM
To: Wolford Lisa
Cc: 'Kathy Pritchard'; 'John Murray'; slater@billslater.com; haytham@puckettfaraj.com
Subject: RE: (Cynowa v. CSSS) Larry Carver Motion

 

Lisa,

 

Other than perhaps the fact that he switched sides in this case, which they clearly know about, Darnella already previewed the lines of inquiry that are the subject of the motion.

 

However, an alternative path is to hold off on the motion and attempt to get Carver to show up for the completion of his deposition.  I am comfortable with this approach if this is the consensus.  If he shows, we can decide after that whether to move forward with a motion to compel him to answer the questions he refused to answer.  One potential downside with that approach is that the Court may be reluctant to grant such a motion if it means he would need to appear for a third time to be deposed.  On the other hand, he might agree to show up and may answer our questions without the need for the motion.  If we pursue this path and he refuses to appear for the completion of his deposition, then we can proceed with the motion to compel.  One issue that may come up is that Theresa Johnson has made some noise in the past about there only being five minutes left in the deposition.  This comes from the misplaced notion that the deposition was a discovery deposition, which is limited to three hours under Illinois rules; in fact, this was an evidence deposition, which is not limited by the three hour rule.  If Carver appears but fails to remain for the completion of his evidence deposition on the notion that there is a three hour limit, we can make a record that we will move to compel and will ask for fees and costs.

 

There is another consideration as well, which is that there is a possibility that Larry Carver may show up in person at trial, despite having sat for an evidence deposition.  This is difficult to predict.  My bet is that the plaintiff will want him there in person.  I also suspect that his ego and animus toward you will drive him to want to be there in person.

 

Also, to answer you last question, we would plan to proceed with the deposition at Haytham’s office in Virginia.

 

Kevin

 


From: Wolford Lisa [mailto:lisa@csss.net]
Sent: Tuesday, January 18, 2011 7:04 PM
To: John Murray; haytham@puckettfaraj.com; slater@billslater.com
Cc: Kevin Duff; Kathy Pritchard
Subject: RE: (Cynowa v. CSSS) Larry Carver Motion

 

John, Haytham and Kevin -

In this we show many of our cards related to Larry.  Which is sure to make him nervous but also give him time to think up other lies.  Is that necessary.  Keeping the element of surprise on our side will put him off his game when he is giving his deposition.  I doubt he will be willing to travel to Chicago.  Are you offering him the opportunity to do it in Haytham and Neal's office in VA?  You are more likely to get compliance that way. 

 

Lisa N. Wolford

CSSS.NET

402-393-8059w

402-393-1825f

SDVOB, 8(a)/SDB & WOB - TS clearances

 


From: John Murray [mailto:jmurray@rddlaw.net]
Sent: Tue 01/18/2011 5:52 PM
To: haytham@puckettfaraj.com; Wolford Lisa; slater@billslater.com
Cc: 'Kevin Duff'; 'Kathy Pritchard'
Subject: (Cynowa v. CSSS) Larry Carver Motion

Lisa, Bill, and Haytham:

 

Attached please find our Motion to Compel Larry Carver to finish his deposition.  Please review and let us know your comments.  Thanks.

 

 

Regards,

 

John E. Murray, Esq.

Associate Attorney

Rachlis Durham Duff & Adler, LLC

542 South Dearborn Street, Suite 900

Chicago, IL 60605

Office: (312) 733-3950

Direct: (312) 275-0338

Mobile: (810) 824-7197

Fax: (312) 733-3952

Email: jmurray@rddlaw.net

Firm website: www.rddlaw.net

 

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