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Thanks very much. The order was filed today.
Nasseem
Ramin From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, June 02, 2010 5:38 PM To: Ramin, Nasseem Cc: Schehr, Thomas; daclaw3@gmail.com; nickhadous@gmail.com Subject: RE: Issa v. GMC You have consent to file the
stipulated order. From: Ramin, Nasseem
[mailto:NRamin@dykema.com] Thanks
very much. And do I have your consent to file the stipulated order on your
behalf? From: Haytham Faraj
<haytham@puckettfaraj.com> Naseem, I agree to a June 18 date to
file your response. Haytham
Faraj, Esq. PUCKETT
& FARAJ, PC WASHINGTON
DC׀
SAN
DIEGO ׀ DEARBORN 313-457-1390
Michigan 888-970-0005
Washington DC 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: Ramin, Nasseem
[mailto:NRamin@dykema.com] Mr.
Faraj, Please find attached
a stipulated order extending GMAC's time to answer or otherwise respond to the
complaint until June 18, 2010. Please confirm that I have your consent to file
this on your behalf. Best, Nasseem Nasseem
Ramin From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] Dear Naseem: I agree to your request for 14 additional days to file your
answer. I understand that you are speaking to your client about a possible
settlement. I am pleased that settlement is a possibility. Please
understand that when I refer to a settlement, I mean good faith negotiations for
reasonable terms. We filed a very detailed pleading. I have ample
evidence documenting GMAC’s failure to exercise good faith when dealing with
Mrs. Issa. Whether it was deliberate or negligent is irrelevant.
I can prove the failures and will let the jury decide the appropriate
damages for GMAC’s bad acts. I lay this out not as a threat but to let you
know that I welcome your offer to negotiate a reasonable settlement and to be
clear that we are prepared to move forward. I look forward to hearing from you. Sincerely, Haytham
Faraj, Esq. PUCKETT
& FARAJ, PC WASHINGTON
DC׀
SAN DIEGO ׀ DEARBORN 760-521-7934
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.
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