Kevin, Thanks and I understand. For Haytham's benefit, I have attached the document I reference. By the way, it could be VERY useful for you to know that Larry Carver called me while I was writing this document. His personal instructions: "Pull out all the stops and BURY Nikiforis with everything you can add to the document." So I did. Best regards, Bill 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 Wed, March 2, 2011 6:29 pm, Kevin Duff wrote: > Bill, > > Thanks for your email. The focus for the summary judgment motion is as we > laid it out in our initial filing on January 19. While the manner in we > you > were treated may be helpful to understanding the context of the events at > issue as we prepare for trial, we do not want to interject new material > into > the summary judgment analysis because we do not want the Court to conclude > that there is a dispute over the facts that a jury must decide. > > I would be happy to discuss this with you tomorrow if you would like to > give > me a call. > > Kevin > > -----Original Message----- > From: William F. Slater, III [mailto:slater@billslater.com] > Sent: Wednesday, March 02, 2011 6:12 PM > To: John Murray > Cc: kduff@rddlaw.net; 'Haytham' > Subject: Re: (Cynowa v. CSSS et al.) Plaintiff's Response Brief in > Opposition to Defendants' Motion for Summary Judgment > > John, > > I have tried to explain in earlier occasions is that the things that > transpired up to and since the termination of Cynowa were a form of > "Workplace Mobbing." (Them against me) > > http://www.mobbing-usa.com/ > > Cynowa's behavior that led to his termination was his attempt to establish > himself as the leader of the gang there. And also to show that he had > contempt for CSSS because the previous Program Manager, Larry McKeehan, > who was Chris' good buddy, was fired. > > It would be very instructive if you could gather evidence in the form of > e-mails, documents, and depositions, etc. that would show how much I was > hated, and subsequently trashed by these people. Also go back and look at > the e-mails that I listed in the Appendix of my March 2007 72-page > response to CSSS regarding Nikoforis' Employee Dispute Resolution against > me. These are e-mails written by the next self-appointed leader of the > gang there. He wanted to have me kicked out in retaliation for the fact > that Cynowa was fired. > > Anyway, you folks need to see what is really going on here and how Cynowa > (and Carver) are using the legal system to finish what they could not > accomplish as a mob in the workplace. > > Thanks, > > 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 Wed, March 2, 2011 4:32 pm, John Murray wrote: >> All: >> >> >> >> Attached please find a copy of the Plaintiff's Response Brief in >> Opposition >> to Defendants' Motion for Summary Judgment. We will begin on our reply >> brief in short order. Please see attached. >> >> >> >> >> >> Regards, >> >> >> >> John E. Murray, Esq. >> >> Associate Attorney >> >> Rachlis Durham Duff & Adler, LLC >> >> 542 South Dearborn Street, Suite 900 >> >> Chicago, IL 60605 >> >> Office: (312) 733-3950 >> >> Direct: (312) 275-0338 >> >> Mobile: (810) 824-7197 >> >> Fax: (312) 733-3952 >> >> Email: jmurray@rddlaw.net >> >> Firm website: www.rddlaw.net >> >> >> >> 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. >> >> >> >> > > > > > > --
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