Great!
There is just one file which is the Agency
investigative report. I should probably just scan it in, although it is thick.
I’ll then e-mail it to you. You already have the only filing from the EEOC. I
was planning on notifying the Agency that we should consolidate the two cases
(the second one is that retaliation claim I mentioned and we haven’t seen the
internal ROI yet but supposedly it is finished), unless you think otherwise. It
does not make sense to me to begin discovery on a case that has a companion
directly connected to it.
We should also meet with the client after
that.
Mark
______________________________________________________________________________
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for such purposes is strictly prohibited. If you have received this
e-mail in error, please notify me immediately by telephone, facsimile or e-mail
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Mark S. Zaid, Esq.
Mark S. Zaid, P.C.
1250 Connecticut Avenue, N.W.
Suite 200
Washington, D.C. 20036
(202) 454-2809 direct
(202) 330-5610 fax
www.MarkZaid.com
From: Debra A.
D'Agostino [mailto:debra@puckettfaraj.com]
Sent: Thursday, November 04, 2010
1:00 PM
To: 'Mark S. Zaid'; 'Eric S.
Montalvo'
Cc: 'Neal Puckett'; 'Haytham
Faraj'
Subject: RE: Debra - co-counsel
money exchange
Mark,
Connie called this morning to say I was
cleared. She wanted to confirm my new contact info, but otherwise good to
go.
How should I arrange to get the relevant
parts of the file?
Debra
From: Mark S. Zaid
[mailto:mark@markzaid.com]
Sent: Thursday, November 04, 2010
1:00 PM
To: 'Eric S. Montalvo'
Cc: debra@puckettfaraj.com; 'Neal
Puckett'; 'Haytham Faraj'
Subject: RE: Debra - co-counsel
money exchange
No problem. I need to get Debra cleared
first so she can even know who the client is. He is covert. I submitted her
paperwork yesterday.
How about we chat tomorrow on the other
matter? I’m free all day.
Mark
______________________________________________________________________________
This electronic mail (e-mail) transmission is meant solely for the person(s) to
whom it is addressed. It contains confidential information that may also
be legally privileged. Any copying, dissemination or distribution of the
contents of this e-mail by anyone other than the addressee or his or her agent
for such purposes is strictly prohibited. If you have received this
e-mail in error, please notify me immediately by telephone, facsimile or e-mail
and purge the original and all copies thereof. Thank you.
Mark S. Zaid, Esq.
Mark S. Zaid, P.C.
1250 Connecticut Avenue, N.W.
Suite 200
Washington, D.C. 20036
(202) 454-2809 direct
(202) 330-5610 fax
www.MarkZaid.com
From: Eric S. Montalvo
[mailto:eric@puckettfaraj.com]
Sent: Thursday, November 04, 2010
12:44 PM
To: Mark S. Zaid
Cc: debra@puckettfaraj.com; 'Neal
Puckett'; 'Haytham Faraj'
Subject: Debra - co-counsel money
exchange
Mark,
Neal
is in court…we did the gymnastics on this and the cleanest way to proceed is a
fee sharing which will need to be signed off on by the client. If you
need language let me know. It is up to Debra and yourself what the agreed
split will be but having the fee agreement addenda or memorandum signed off on
by the client is key. K work is not the way to go due to the fact that
Debra will be acting as attorney of record and has a direct and independent
duty to the client as opposed to "drafting a motion" for you to
review and submit with your signature making you responsible for the work
product. I can flesh out more if needed. I also need to chat with
you re the other case I cc'd you on.
V/r
E
Eric
S. Montalvo
Attorney
at Law
1800 Diagonal Road
Suite
210
Alexandria,
VA 22314
eric@puckettfaraj.com
(703)
706-9566 Phone
(540)
840-7717 Cell
(202)
318-7652 Fax
DC ׀ CA ׀ MI ׀ VA
www.PuckettFaraj.com
Practice is limited to matters and
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