Haytham: I have a few questions:
1. I have attached the Complaint with the client's changes accepted, but please note: I deleted trial by jury since a determination on an injunction is a matter of law. That's why I had Trial by Jury in brackets on my last draft. Also, I wanted to search some more to see if there was a "property right" Constitutional argument to be made. I think it would be under the Fifth Amendment since the 14th and 42 USC 1983 only apply to state action. If you are comfortable that we can file an amended complaint (assuming I find a ground for suit), then I'm ok with filing now. Otherwise, I'd like just a little more time with this. I got your DC Bar # from Mariam and signed Complaint and Cover Sheet so I could attach the PDFs. It's been a while since I filed a Federal Complaint, but I am guessing that when you sign in to file it on the ECF you give it a credit card for the filing and service fees?
2. You can't serve the Motion for Prelim Injunction till you serve the complaint. I understand that you want me to make any requested changes to the Memo and for filing at the appropriate time.
3. I am really trying to recover from a nasty case of stomach flu that I got on Sunday. I will only be here till 2:00 EST because I'm kind of having trouble focusing. Since we can't file it at this point anyway, I did not send you the Motion for Prelim Injunction because I have not reviewed it yet. I wanted to wait on that till I can think straight, which will hopefully be tomorrow. I hope this is ok.
Mary Jo
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, January 17, 2012 10:29 AM
To: 'MaryJo Provenzano'
Subject: CSSS law suit
Mary Jo,
I am attaching the Complaint and injunction for CSSS. Please correct the heading to reflect the actual name of the company. Please prepare the civil cover sheet and get this ready for filing. I would like it filed today if possible so as soon as you finish everything, email me the PDF documents so I can review and file.
Thank you
Haytham Faraj, Esq.
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