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RE: Debra - co-counsel money exchange



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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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

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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

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