| Will not share email, of course. I'm still not getting it. So he wants to remain engaged means he does NOT want to pretend to be unavailable (unless retained or recalled) for purposes of the motion? Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Aug 17, 2010, at 10:44 AM, Haytham Faraj wrote: Hey partner, What I meant by not cooperating is that he wants to be there next week and to be involved. I meant that he is reluctant to cooperate with us by remaining engaged. He thinks I could do it. Although in theory it could be an issue. Practically speaking, I am a member of the firm that has now taken on representation. We have a retainer agreement with Frank that Colby doesn’t have. I see me and him as distinct issues. Speak to him today if you can and let me know what impression you have. Don’t share with him the substance of this email. I think the thing to do is for him to stay home next week. There’s really nothing for him to do any way since he didn’t write any of these motions. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Tuesday, August 17, 2010 6:57 AM To: Haytham Faraj Subject: Re: Motion to dismiss re. loss of counsel I sent him an email last night, cc:ing you, in which I asked him NOT to cooperate. How is that inconsistent with his desire NOT to cooperate? What is best for the case for our client should be our guide. Dwight Sullivan believes this is a no-shit real issue in our case. My position is that Colby should stay home next week in order to make that issue real enough for a chance to win it with Jones. It really is a moot issue if he's working the case anyway. There would be no showing of prejudice, which, according to Sullivan, might be the issue that CAAF uses to reverse the Hutchins ruling. Depending on how Jones handles it, like if he just shuts it down by denying the motion, then we can decide whether to moot the issue by inviting his participation in the trial anyway. We can't let sentimentalities get in the way of the mission. I think we should talk about it. Like you, I also don't want to burn bridges. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Aug 17, 2010, at 12:24 AM, Haytham Faraj wrote: Colby, Is not willing to cooperate on this. He fears being recalled to active duty. I am not sure why that is because such a course of action is unlikely. But even if they recall him we can always withdraw the motion which would moot the issue. I am not sure if there’s something else there. I’d like to know what your position is on this. I feel strongly about it because I think it’s a valid issue with merit. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |