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RE: CSSS Inc case



Are we going to see the motion before he files it? 

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, January 04, 2011 7:15 PM
To: 'Debra D'Agostino'
Subject: RE: CSSS Inc case

 

The motion to dismiss is the next step.  He’s supposed to be working on it.

 

From: Debra D'Agostino [mailto:debra@puckettfaraj.com]
Sent: Tuesday, January 04, 2011 6:02 PM
To: 'Haytham Faraj'
Subject: CSSS Inc case

 

I cannot believe co-counsel has not filed a Motion to Dismiss.  In essence, it’s a defamation claim, and the entire allegation is that after the guy was fired, someone in management told a Police Officer that the plaintiff had a temper and mentioned having an AK-47.  The Police Officer then wrote a statement that he was dispatched to escort the guy because his employer thought he might lash out (which he calls written defamation). 

 

This does not even meet the definition of defamation, and the damages he's seeking are from loss of his job - which is not even a claim!

 

When we spoke with co-counsel, he was focused on finding experts to counter the damages claims - but I can't even see how there are damages.  The idea that this guy would pay an expert is mind boggling.

 

I don't know anything about Illinois law, but I'm presuming we can and should still file a Motion to Dismiss or for Summary Judgment.

 

 

Debra A. D'Agostino
Partner

 

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