Haytham, Welcome to the Legal Team. Kevin and his colleagues have done an outstanding job. A few things you should konw: 1) Flanagan was a natural-born trouble-maker and back-stabber who hated me with a passion. 2) Flanagan's Affadavit (attached) isn't worth the paper it was written on. It was coached by Theresa Johnson, but carried with it all the venom and vitriol that Flanagan had against me. 3) Flanagan had an extremely mean nature and loved to gossip, make up lies, and stir up trouble. 4) After Flanagan became a VA Government Employee in December 2007, he and Mike Cronin later engaged in an open air dialog that was abusive and demeaning regarding a new employee (Mary Smith) that I was indocrinating on March 2, 2008. I reported their behavior to our boss, Jerry Taylor (VA Employee). He scolded Flanagan and Cronin for this behavior, both together and individually. Flanagan, a short time later, went around and told everyone that he had been been scolded for this incident. 5) To help you better understand the dynamics of the workplace behaviors and what was really going on, pPeople in the workplace in Chicago will often engage in the Mobbing Behaviors described in these sources: Leymann's Topology of Mobbing (They were at stage three.) http://untamedteacher.blogspot.com/2009/01/mobbing.html http://www.amazon.com/Mobbing-Emotional-Abuse-American-Workplace/dp/0967180309/ref=sr_1_1?ie=UTF8&qid=1295364593&sr=8-1 5) Cynowa was upset because he was the "Lead Dog Asshole" and getting terminated shut him down. After a few weeks of chaos, Nikiforis rose up to take his place, and after Nikiforis left, Flanagan stepped up. If you want to call me, I welcome a chat. You should also spend some time checking me out at http://billslater.com/ and http://billslater.com/career and at http://billslater.com/myusaf People like Nikiforis, Cynowa, and Flanagan hated me because of my accomplishments and my website. I am a good guy and it is a shame that myself, Lisa Wolford and CSSS have been put through this garbage lawsuit. I am also forwarding you an e-mail that I wrote to Kevin, John, and Lisa, during my three-week trip to Poland between December 18, 2010 and January 9, 2011... Please look for it. Best regards, William F. Slater, III, PMP Chicago, IL United States of America slater@billslater.com http://billslater.com http://billslater.com/career 773 - 235 - 3080 - Home 312 - 758 - 0307 - Mobile On Tue, January 18, 2011 7:51 am, Haytham Faraj wrote: > Kevin, > > This is very well written. It's comprehensive in its coverage of the > issues. > Well done! I only have a couple of comments. at page 12 2nd Paragraph > under E, you say "it is beyond cavil." Not sure what cavil means. Also, > is > it possible to get an affidavit from Noel Flanagan regarding the statement > to Bill Slater. > > > > The reason I wanted to take a look at Cynowa's military record and DD-214 > is > because of statements he made in his deposition that raised serious doubts > in my mind about his service. 1) The term MOS is burned into the memory > of > service members. It stands for military occupational specialty. He said > it > stands for "method of service" Depo. P. 37, line 20. The reason people > know > and remember that term is because you spend the first few weeks and > sometimes months of your military life competing to get the MOS you > desire. > And you spend the rest of your military career working to remain > competitive > and relevant in your MOS. There is no way someone would forget what that > stands for. Also the entire exchange at the truck with officer Androwski > is > odd. Most Marines who come across another Marine would engage in > conversation about a) the MOS they had; b) the units they served in; c) > the > locations and dates they served. Of course he did not serve in the Marine > Corps -he served in the Army- yet he has a Marine Corps sticker on his > truck. 2) He says he may have fired an AK-47 in boot camp. Boot camp is > not a memory that is easily forgotten even with the passage of time. > Neither the Army nor the Marine Corps fire soviet (in 1985) weapons in > their > basic training. I went to boot camp in 1986. I, as well as my friends > from > boot camp, have specific memories and details from boot camp. I remember > the day when I first fired a weapon and my time on the rifle ranges. Mr. > Cynowa says he did not compete Marine Corps boot camp. I have some doubts > about whether Mr. Cynowa completed any full term of service in the > military > at all. > > > > From: Kevin Duff [mailto:kduff@rddlaw.net] > Sent: Monday, January 17, 2011 7:09 PM > To: lisa@csss.net; slater@billslater.com; 'Haytham' > Cc: 'John E. Murray'; 'Kathleen M. Pritchard' > Subject: Cynowa v. CSSS, et al. -- draft summary judgment brief & Slater > affidavit > > > > Lisa, Bill, and Haytham, > > > > Attached are: (i) the summary judgment brief along with (ii) an affidavit > for Bill Slater. Please let me know any comments you have as soon as > possible. Ideally, I would like to file the motion tomorrow. > > > > Please note that we are subject to a 15-page limit on the brief. > > > > Kevin > > > > > > > > Kevin B. Duff > > Rachlis Durham Duff & Adler, LLC > > 542 South Dearborn Street, Suite 900 > > Chicago, Illinois 60605 > > phone: 312-733-3390 > > fax: 312-733-3952 > > mobile: 312-218-8620 > > > > > > RACHLIS DURHAM DUFF & ADLER, LLC E-MAIL CONFIDENTIALITY NOTICE > > > > This transmission may be: (1) subject to the Attorney-Client Privilege, > (2) > an attorney work product, or (3) strictly confidential. If you are not the > intended recipient of this message, you may not disclose, print, copy or > disseminate this information. If you have received this in error, please > reply and notify the sender (only) and delete the message. Unauthorized > interception of this e-mail is a violation of federal criminal law. > > --
Attachment:
Cynowa - Affidavit (Signed) re Flanagan 110910 0340pm.pdf
Description: Adobe PDF document