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Mediation statement - possible areas of agreement



Hello Mr. Rosenblum,

I am an associate for Puckett & Faraj. We met previously at a hearing for 3D v. MVM. I hope you are well. I am working on the mediation statement for 3D v. MVM and wanted to run the areas of agreement section by you to see if you agree, or have anything to add:

Possible Areas of Agreement:
1. A contract existed between MVM and 3D Global, and between MVM and the United States Government. 2. 3D recruited 230 TCNs for MVM pursuant to the agreement that existed between them.
3. MVM received, employed, and deployed all of the TCNs.
4. 3D invoiced MVM for performance of the pre-deployment services pursuant to the contract between them.
5. The United States Government sued MVM for breach of contract.
6. MVM argued that they did not breach their contract.
7. MVM and the United States Government came to a settlement in which they agreed that the contract between them had been terminated for the convenience of the United States Government. 8. MVM and 3D agree that no breach of contract occurred between MVM and the United States Government.
9. MVM has not paid 3D for the invoiced amount.

I have cc'ed Haytham on this email in case he has anything he would like to add. I look forward to hearing back from you soon.

Thank you,

Carolynn Beck
(202) 316-1367