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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

Attachment: Draft_1.doc
Description: MS-Word document




Carolynn Beck
(202) 316-1367