RE: CSSS

Kevin.

I closed today. We're waiting for a verdict. I will call you tomorrow afternoon. I'll use the morning to get caught up.

Haytham Faraj

Sent from my iPhone

On Jan 13, 2011, at 8:33 PM, "Kevin Duff" <kduff@rddlaw.net> wrote:

Haytham,

I hope your trial is going well. I look forward to speaking with you when you become available. We have made substantial progress on the summary judgment motion. We also were able to speak with Bill Slater this evening to go over his affidavit. While I wanted to file the summary judgment motion this week, under the local rules we actually have until January 26 to get it on file. I expect to have a draft to circulate by the end of the day tomorrow. The courts are closed on Monday, so I am aiming for a Tuesday filing.

While the summary judgment motion is our priority right now, I also hope to send you a draft of the Carver motion tomorrow.

Kevin

From: Kevin Duff [mailto:kduff@rddlaw.net]
Sent: Monday, January 10, 2011 8:43 AM
To: 'Faraj Haytham'
Cc: 'lisa@csss.net'; 'Kathy Pritchard'
Subject: CSSS

Haytham,

I received your voice message. I will look forward to hearing from you mid-week when your trial is over.

In the meantime, I will be sending you a draft motion for summary judgment for your comments. We need to file this motion this week.

I will also send you a draft motion to compel Larry Carver to appear for the completion of his evidence deposition. Lisa and I have discussed having you complete this deposition, so we will need to discuss your availability before the date and location for this deposition get set.

Good luck with your trial.

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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