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Haytham: I have worked on the attached draft Complaint and send it to you in case you have some time to look at it over the weekend. I do not consider this a finished product but am interested in your comments as to whether I am going in the right direction. Also, I believe once I have the Complaint done, we should also file a Motion for Mandatory Injunction asking for the relief requested in the Complaint in the form of a preliminary mandatory injunction for CVE to : 1. issue a final ruling on the application after reviewing the request for reconsideration, and 2. reinstated CSSS.net to VETBIZ. I think to do this I need some information from Lisa regarding the amount of damage or potential damage that is being done to her business because of the agency's arbitrary and capricious failure to do what it's supposed to do. Do you agree? If so, I will get you a draft motion early next week, but to complete it I'm probably going to need some "damage" info from Lisa. Mary Jo Provenzano Paralegal PUCKETT & FARAJ, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax 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. |
Attachment:
COMPLAINT CSSS v VA.rtf
Description: MS-Word document