Haytham: I did some additional editing. I thought it said too much and so I trimmed it down some. I have put two questions in yellow highlighting. One - We were given the Chairman's home phone number and it seems like it would not be a good idea to give that number out since there was a lot of animosity toward the Chair. Do you agree? Also, I think that Abed Ayoub should not be listed as a witness since he was providing legal advice and should be covered by attorney client privilege. Do you agree? Mary Jo Provenzano Paralegal PUCKETT & FARAJ, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax www.puckettfaraj.com DC ׀ CA ׀ MI ׀ VA twitter.com/puckettfaraj Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Thursday, December 08, 2011 10:03 AM To: 'MaryJo Provenzano' Subject: RE: Disclosures ADC Mary Jo, Please review the initial disclosures for ADC. There are a number of grammatical and syntax mistakes. I was trying to edit but in some instances the it is not very clear what the intent is. I do not want to make edits that change the meaning of what is intended. -----Original Message----- From: MaryJo Provenzano [mailto:maryjo1@puckettfaraj.com] Sent: Wednesday, December 07, 2011 11:22 AM To: 'Haytham Faraj' Subject: RE: Disclosures ADC Haytham: I have edited the disclosures a bit, in an effort not to say too much. However, here they are completed. Please let me know if you agree with the stuff I cut out. I can filed this for you - are you coming back in today or are you gone? If you're gone, I need to figure out how to get your electronic signature to paste onto the document. I will work on the Requests for Admissions and Amended Answer and send those to you later. I'm not sure I agree with you on the laches thing. Thanks. Mary Jo Provenzano Paralegal PUCKETT & FARAJ, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax www.puckettfaraj.com DC ׀ CA ׀ MI ׀ VA twitter.com/puckettfaraj Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, December 07, 2011 6:58 AM To: 'MaryJo Provenzano' Subject: FW: Disclosures Hi Mary Jo, Please use the attached to prepare the disclosures. I think once you review this information you will find additional matters to put in the discovery requests. For example, a request for admission that Jandali personally saw or learned that the ADC website included his YouTube video but that he did not object. I also think we may need to amend our answer to include laches. -----Original Message----- From: Abed Ayoub [mailto:abedayoub@gmail.com] Sent: Wednesday, December 07, 2011 3:49 AM To: Haytham Faraj Subject: Disclosures Haytham, Attached you will find the disclosure request, along with an additional document with some of the information. Most of the material is attached. I am working on getting together the rest of the facebook postings -- and any additional details from those involved with the matter. I will print out a copy and bring it with me tomorrow. See you in the morning, Abed
Attachment:
Initial Disclosure- Defendant.rtf
Description: MS-Word document