Haytham--As I previously noted, I no longer represent Brian on this matter. You should contact his current counsel, Amy Tabor, atabor@sohlawfirm.com, phone 832-377-7334. Bert
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Saturday, January 21, 2012 09:41 AM
To: Tabor, Albert
Subject: RE: Concal_Brain Savino/Mike Dodd
Bert, I would like to chat with you regarding the Dodd-Savino matter. Mr. Dodd is interested in settling the matter and has requested that I try and work with you on the matter. Please let me know if you’re available today. Thank you. From: Tabor, Albert [mailto:atabor@velaw.com]
Sent: Monday, November 14, 2011 11:20 AM
To: Haytham Faraj (haytham@puckettfaraj.com)
Subject: FW: Concal_Brain Savino/Mike Dodd Call Haytham, I no longer represent Brian on this matter. He is now represented by Amy Tabor at Schiffer, Odom, Hicks & Johnson. Thank you for your courtesies over the last few weeks. I'm sorry that an amicable solution could not be worked out. Bert
From: Michael Dodd [mailto:mike.dodd@3dglobalsolutions.net]
Sent: Friday, November 11, 2011 5:20 PM
To: 'Savinbj@mac.com'; Tabor, Albert
Subject: Re: Concal_Brain Savino/Mike Dodd Call Brian,
I was very specific with you;
Have your attorney work with Haytham. We are quite comfortable with our legal position no matter which direction is taken.
The scenario as you have outlined seems reasonable, as such I encourage you once again to have your attorney work with Haytham to bring this to closure.
Mike Dodd
CEO 3D Global Solutions
212-729-6959
Sent from my Blackberry
From: Brian Savino [mailto:savinbj@mac.com]
Sent: Friday, November 11, 2011 11:03 AM
To: Michael Dodd
Subject: Concal_Brain Savino/Mike Dodd Call
Mike; My note to you was very specific. I am not going through any further delays or non-performance on your behalf, and I am not going to spend any more money having my counsel draft-up documents that you that you eventually do not respond to. I clearly stated that I will have my attorney draft the docs on one condition and only that one condition being satisfied, and that is: "I - MIKE DODD HAVE READ, AGREE WITH, AND CONFIRM ALL THE TERMS AND DEMANDS OF THE SETTLEMENT OFFER (ATTACHED and highlighted in RED):" YES: ______________ OR NO: ____________ If you wish, you can send an email and copy-in Haytham that you are in AGREEMENT with my proposal, and on the basis of your agreement, I'll have the docs prepared for signatures / execution. There is no room for and deviation, and its your choice to accept or reject. I'm not going through attorneys' -- I'm speaking directly to the person I negotiated the deal with, and would hope that we can reach an agreement we'll both perform against. Either way, the offer expires at COB today if I do not get an acceptance from you or there's no reply. Consistent with advice rendered by my litigation attorney I've now engaged, as you've been aware, I can not take your advice as an acceptance, on how you've responded. I would therefore appreciate your confirmation to the full offer enclosed with a small caveat, I'd like to include $1,000.00 US for legal fees incurred, which will be included within the 5 monthly payments, bringing the monthly payments to $31,700.00/month. If you agree, your written confirmation of same is required (by an appropriate email) warranting that you have reviewed, and agree to, and confirm your full acceptance of same. At this / that juncture, I'll have my attorney draft the docs for execution, and send them to both yourself and Haytham for execution. You can call me to discuss any aspect of this agreement if you deem it's pertinent, but, once again, it's non-negotiable. You can advise me anytime prior to Close-of-Business - Friday - November 11th, 2011 of your official acceptance, and if I have no response from you at that time, I'll instruct my attorney to proceed. I hope we settle this amicably, and you find this offer acceptable. Look forward to your positive response....
Best regards, Brian,
Are you having your attorney write this up and forwarding to Haytham? Pls advise
Mike Dodd
CEO 3D Global Solutions
212-729-6959
Sent from my Blackberry
From: Brian Savino [mailto:savinbj@mac.com]
Sent: Wednesday, November 09, 2011 10:21 AM
To: Michael Dodd
Cc: Melissa Katz
Subject: Concal_Brain Savino/Mike Dodd Call
Mike; As advised, I'm not certain I'll be available @1630 Houston time, and therefore would not like to commit. I've waited 5 days now for your call; to NO AVAIL. I was going to make one final attempt to resolve your debt payment to me, but you do not seem to have time and/or interest to make a phone call to me during the prearranged times we've set -- as per my note attached. There's an offer attached for your consideration and acceptance -- if you so choose. I may be available at whatever time you wish to call this afternoon, but since the attached was what I want5ed to reference and offer, and since you can't make the call between 1000 and 1030 Houston Time this morning, you can have till Close-of-Business today (Houston Time) to either accept the offer -- in writing -- or if (as I anticipate) there's no conversation between you and I for the balance of today, I'll proceed to collect my funds due, interest, attorney fees, and whatever else possible through an alternative venue.
<top_l.gif> | <top_li.gif> | | <spacer.gif> | <top_r.gif> | <spacer.gif> | <spacer.gif> | <spacer.gif> | Conversation with Mike... Originally ==> 04 NOV 11....Friday.....1500-1700 - Mike never called / Subsequently arranged for Houston time.......Monday...November 7th, 2011 - BJS called Mike - left message - Mike never called / Then set-up for Tuesday between 1400 - 1500 Houston time.....Mike never called. Brian offered availability between 1000-1030 Houston Time, and Mike could not make himself available for a call during this time horizon.
Offer to Mike Dodd:
Mike - Was expecting your call on Friday and then subsequently on Monday, and then Tuesday, and was hoping we could achieve an amicable agreement that you'll perform against, by the end of the scheduled call. Since I did not receive a call nor communication, I thought / assumed you had no interest in speaking. However, glad to make one more attempt. I / we can only assume that you are struggling with "cash flow," and this is the basis of you not sending the funds required by the 3rd of November, 2011. I'd like to set the conditions of evolving the $150,000.00 "earnest funding" into a Corporate (3DGS) / Personal Loan: 1.) Payments to be received by B. Savino (Chase Bank Acct.) by the last business day of the month (commencing Nov. 2011); 2.) Terms of repayment should be at an interest rate of 5% ... Therefore monthly payments will be $ 31,700.00 US / month, inclusive of $1,000.00 US attorney fees; 3.) Late payment allowance will be 3 business days; whereby funds need to be received by the 3rd business day of the month following due date month, if funds have not been received by the 4th business day, "default," and full balance plus interest is due within the next two business days or by the 7th business day of the month following month in which funds were due; 4.) Loan duration ==> 5 months: NOV / DEC - 2011 / JAN - FEB - MAR - 2012; I'm free to discuss at your convenience throughout today, however the offer is non-negotiable. I'll set a time limit of 1700 Houston time Wednesday / November 9th ==> for your written acceptance of above terms, which will be documented for signature validation / execution. If there is no advice from either you and/or Haytham, I'll assume you've rejected this loan offer. |
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On Nov 9, 2011, at 8:49 AM, Michael Dodd wrote:
Mike will call Brian to initiate the call
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