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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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