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RE: Cynowa v. CSSS, et al. -- draft summary judgment brief & Slater affidavit
Lisa,
No Ma'am - I believe that his military service started and ended with that
8-week stint in the U.S. Marine Corps.
Respectfully,
Bill
On Tue, January 18, 2011 3:23 pm, Wolford Lisa wrote:
> Yes but I think that he later served in the Army, isn't that true?
>
> Lisa N. Wolford
> CSSS.NET
> 402-393-8059w
> 402-393-1825f
> www.csss.net <http://www.csss.net/>
> SDVOB, 8(a)/SDB & WOB - TS clearances
>
> ________________________________
>
> From: William F. Slater, III [mailto:slater@billslater.com]
> Sent: Tue 01/18/2011 3:14 PM
> To: Wolford Lisa
> Cc: Kevin Duff; Haytham Faraj; slater@billslater.com; John E. Murray;
> Kathleen M. Pritchard
> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
> Slater affidavit
>
>
>
> Lisa, et al,
>
> I got this from Cynowa when he worked for me:
>
> 1) Cynowa was on active duty as a U.S. Marine Corps recruit for about 8
> weeks.
>
> 2) He was injured in Basic Training. Messed up his knee.
>
> 3) His DD-214 would indicate the number of days of his military service
> and the character of his discharge.
>
> 4) By the way, under the definition of what a veteran is in the U.S.
> Department of Veteran of Affairs, you must have served on active duty more
> than 181 days. He did not, so he is not not a veteran and not eligible
> for VA benefits.
>
>
> Best regards,
>
> Bill
> William F. Slater, III, PMP
> Chicago, IL
> United States of America
> slater@billslater.com
> http://billslater.com <http://billslater.com/>
> http://billslater.com/career
> 773 - 235 - 3080 - Home
> 312 - 758 - 0307 - Mobile
>
>
>
> On Tue, January 18, 2011 2:44 pm, Wolford Lisa wrote:
>> It is a FOIA request. I responded before I saw your earlier email...
>>
>> Lisa N. Wolford
>> CSSS.NET
>> 402-393-8059w
>> 402-393-1825f
>> www.csss.net <http://www.csss.net/>
>> SDVOB, 8(a)/SDB & WOB - TS clearances
>>
>> ________________________________
>>
>> From: Kevin Duff [mailto:kduff@rddlaw.net]
>> Sent: Tue 01/18/2011 1:28 PM
>> To: Wolford Lisa; 'Haytham Faraj'; slater@billslater.com
>> Cc: 'John E. Murray'; 'Kathleen M. Pritchard'
>> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
>> Slater affidavit
>>
>>
>>
>> Is that a FOIA request or is such a request made in another way?
>>
>>
>>
>> ________________________________
>>
>> From: Wolford Lisa [mailto:lisa@csss.net]
>> Sent: Tuesday, January 18, 2011 1:17 PM
>> To: Kevin Duff; Haytham Faraj; slater@billslater.com
>> Cc: John E. Murray; Kathleen M. Pritchard
>> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
>> Slater affidavit
>>
>>
>>
>> You can request his records from National Personnel Records in St. Louis
>> MO. He must have a DD214 or he is lying and didn't serve....
>>
>>
>>
>> Lisa N. Wolford
>>
>> CSSS.NET
>>
>> 402-393-8059w
>>
>> 402-393-1825f
>>
>> www.csss.net <http://www.csss.net/>
>>
>> SDVOB, 8(a)/SDB & WOB - TS clearances
>>
>>
>>
>> ________________________________
>>
>> From: Kevin Duff [mailto:kduff@rddlaw.net]
>> Sent: Tue 01/18/2011 12:33 PM
>> To: Wolford Lisa; 'Haytham Faraj'; slater@billslater.com
>> Cc: 'John E. Murray'; 'Kathleen M. Pritchard'
>> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
>> Slater affidavit
>>
>> We requested that he produce his military records. He said he does not
>> have any.
>>
>>
>>
>> ________________________________
>>
>> From: Wolford Lisa [mailto:lisa@csss.net]
>> Sent: Tuesday, January 18, 2011 11:51 AM
>> To: Haytham Faraj; Kevin Duff; slater@billslater.com
>> Cc: John E. Murray; Kathleen M. Pritchard
>> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
>> Slater affidavit
>>
>>
>>
>> Kevin -
>>
>> Didn't we get a copy of Cyanowa's DD214?
>>
>>
>>
>> Lisa N. Wolford
>>
>> CSSS.NET
>>
>> 402-393-8059w
>>
>> 402-393-1825f
>>
>> www.csss.net <http://www.csss.net/>
>>
>> SDVOB, 8(a)/SDB & WOB - TS clearances
>>
>>
>>
>> ________________________________
>>
>> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
>> Sent: Tue 01/18/2011 7:51 AM
>> To: 'Kevin Duff'; Wolford Lisa; slater@billslater.com
>> Cc: 'John E. Murray'; 'Kathleen M. Pritchard'
>> Subject: RE: Cynowa v. CSSS, et al. -- draft summary judgment brief &
>> Slater affidavit
>>
>> Kevin,
>>
>> This is very well written. It's comprehensive in its coverage of the
>> issues. Well done! I only have a couple of comments. at page 12 2nd
>> Paragraph under E, you say "it is beyond cavil." Not sure what cavil
>> means. Also, is it possible to get an affidavit from Noel Flanagan
>> regarding the statement to Bill Slater.
>>
>>
>>
>> The reason I wanted to take a look at Cynowa's military record and
>> DD-214
>> is because of statements he made in his deposition that raised serious
>> doubts in my mind about his service. 1) The term MOS is burned into
>> the
>> memory of service members. It stands for military occupational
>> specialty.
>> He said it stands for "method of service" Depo. P. 37, line 20. The
>> reason people know and remember that term is because you spend the first
>> few weeks and sometimes months of your military life competing to get
>> the
>> MOS you desire. And you spend the rest of your military career working
>> to
>> remain competitive and relevant in your MOS. There is no way someone
>> would forget what that stands for. Also the entire exchange at the
>> truck
>> with officer Androwski is odd. Most Marines who come across another
>> Marine would engage in conversation about a) the MOS they had; b) the
>> units they served in; c) the locations and dates they served. Of course
>> he did not serve in the Marine Corps -he served in the Army- yet he has
>> a
>> Marine Corps sticker on his truck. 2) He says he may have fired an
>> AK-47
>> in boot camp. Boot camp is not a memory that is easily forgotten even
>> with the passage of time. Neither the Army nor the Marine Corps fire
>> soviet (in 1985) weapons in their basic training. I went to boot camp in
>> 1986. I, as well as my friends from boot camp, have specific memories
>> and
>> details from boot camp. I remember the day when I first fired a weapon
>> and my time on the rifle ranges. Mr. Cynowa says he did not compete
>> Marine Corps boot camp. I have some doubts about whether Mr. Cynowa
>> completed any full term of service in the military at all.
>>
>>
>>
>> From: Kevin Duff [mailto:kduff@rddlaw.net]
>> Sent: Monday, January 17, 2011 7:09 PM
>> To: lisa@csss.net; slater@billslater.com; 'Haytham'
>> Cc: 'John E. Murray'; 'Kathleen M. Pritchard'
>> Subject: Cynowa v. CSSS, et al. -- draft summary judgment brief & Slater
>> affidavit
>>
>>
>>
>> Lisa, Bill, and Haytham,
>>
>>
>>
>> Attached are: (i) the summary judgment brief along with (ii) an
>> affidavit
>> for Bill Slater. Please let me know any comments you have as soon as
>> possible. Ideally, I would like to file the motion tomorrow.
>>
>>
>>
>> Please note that we are subject to a 15-page limit on the brief.
>>
>>
>>
>> Kevin
>>
>>
>>
>>
>>
>>
>>
>> Kevin B. Duff
>>
>> Rachlis Durham Duff & Adler, LLC
>>
>> 542 South Dearborn Street, Suite 900
>>
>> Chicago, Illinois 60605
>>
>> phone: 312-733-3390
>>
>> fax: 312-733-3952
>>
>> mobile: 312-218-8620
>>
>>
>>
>>
>>
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>>
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>>
>
>
> --
>
>
>
>
>
--
Best regards,
Bill
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
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