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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
Associate Dykema 400 Renaissance Center Detroit, MI 48243 Phone: 313.568.5326 Fax: 313.568.6701 nramin@dykema.com www.dykema.com From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Tuesday, June 01, 2010 6:48 PM To: Ramin, Nasseem Cc: 'David Chami'; 'Nick Hadous' Subject: Issa v. GMC 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
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