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All else is actually fine From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] Mike take a look at the language below. I intend to
send this to Rosenblum. Please let me know what you think or if we need
more clarification. The numbers are just space fillers. I need you
to put in the numbers that you believe are realistically obtainable based on
your experience. “There has been no progress since our last session. We
are coming up on a status report date to the judge. I have a proposal
that I believe can help us get to a settlement consistent with the agreement we
came to before we last adjourned. This is based on the assumption that
your client continues to intend to cooperate on developing business. 3D
Global is a service Disabled Veteran Owned Small Business. As such it is
eligible for certain set aside government contracts that other businesses would
not be able to compete for or would face substantial challenges obtaining.
Accordingly, it is our position that 3D can provide to MVM certain
opportunities that may not be available otherwise. 3D will agree to
conditionally dismiss its law suit in return for MVM depositing $100,000 into
an escrow account that shall be released to 3D upon 3D and MVM winning a
contract or contracts worth no less than 1.5 million dollars. If within
18 months of the fund being escrowed, 3D is not able to win a contract using
MVM’s capabilities and past performance or cannot present MVM with at least 2
viable contract opportunities, the money will be returned to MVM. 3D must
present 2 viable contract opportunities during the 18 months period. If
MVM declines to participate, the funds will transfer to 3D at the conclusion of
18 months. There will be more details to be worked out but I think this
captures the essence of our offer. Please let me know.” 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
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