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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/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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