I'll take a look over the weekend, I've been scrambling to finish up a few complaints and some miscellaneous bankruptcy work.
On Thu, May 20, 2010 at 8:59 AM, Haytham Faraj
<haytham@puckettfaraj.com> wrote:
Would you review this motion for me if you have couple of minutes? Your
input is appreciated.
-----Original Message-----
From: Carolynn Beck [mailto:carolynn.beck@gmail.com]
Sent: Wednesday, May 19, 2010 8:07 PM
To: Haytham Faraj
Subject: VERY rough draft of opposition
Haytham,
I wanted to send this to you so you have an idea of where I am with my
draft. Obviously, it's a very rough draft/still in progress, but I started
writing things out as I was discussing with Wissam and as I was researching,
so that I could have it all in one document and thought you might want to
know my progress/thought process.
I am waiting on Wissam to let me know who he was able to get ahold of and if
he got any agreements to testify. Please let me know if you have any input
or notice that I missed anything, especially regarding the bold/underlined
portions, where I am either waiting on a response from Wissam, or had
questions for you. I am still going to go back and
proofread/reorganize/reformat everything once I have all the information
together, so please don't worry about the format or wording (unless there's
something huge that you are really concerned about and want to make sure I
go over when I'm reworking this).
Specifically, I'd like to know whether all of the claims Wissam had against
other parties were dismissed. The question only comes up in regard to the
conspiracy/concert of action claim. Since the summary disposition doesn't go
into depth regarding those counts, and from what I am aware, the claims
against Wayne County and Sheriff Warren Evans have been dismissed, are we
only claiming concert of action/ conspiracy between Doug Bucher and Macy's?
Either way, I am assuming I will need additional information from Wissam,
but wanted your input/ guidance/suggestions regarding that claim too.
Thank you,
Carolynn
--
Nick N. Hadous
Mobile (MI): (313) 415-5559
Mobile (AZ): (602) 492-4432
Email:
nickhadous@gmail.com