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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] 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 phone: 312-733-3390 fax: 312-733-3952 mobile: 312-218-8620 RACHLIS This transmission may be: (1) subject to
the Attorney-Client Privilege, (2) an attorney work product, or (3) strictly
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