Haytham: I highlighted in yellow the edits to the Rule 26 report. There were other affirmative defenses, but I do not believe they are based in statutory law. I am attaching a case indicating that implied licenses are part of a judicial doctrine. Also it appears that two of our defenses relate to the same USC section so I put them together. I am still looking to see if I can find any basis in statute other than Rule 12(b)(6) regarding there being no damage to Plaintiff. 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. From: Haytham Faraj [mailto:haytham@puckettfaraj.com] I should have it to you today with our recommended additions and changes. Thank you. From: McNutt, Steve [mailto:Steven.McNutt@troutmansanders.com] Haytham: I write to follow up on the draft 26(f) report. It is due to be filed tomorrow. Please let us know if it is acceptable to the ADC. Regards,
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Thanks. I'll review today and get back to you on it. Haytham Faraj Sent from my iPhone
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CASE Gilbert v Accent Builders.doc
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Jandali_ Draft Joint 26(f) Report.11-14-2011.doc
Description: MS-Word document