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Jandali v. ADC Request for Admissions



Haytham:

 

I updated the RFA’s a little, but we already had a request for him to admit that he had knowledge about the embedded YouTube post.  I just tweaked it a little. I also added Request 19 that references the page from Facebook where he admits to knowing about the proposed broadcast of the YouTube post prior to the Convention, assuming that we can get Mr. Ayoub to get it to us.

 

I am also wondering if we might have a Rule 11 claim here.  This is clearly a frivolous lawsuit that Mr. Jandali filed to “punish” the ADC.  He has misrepresented the facts about being disinvited and being censored by the ADC (I think this is what is in the Facebook page, judging from the backlash I found on the social media from his fans’ blogs – see attached.)  His attorneys knew or should have known that there was no claim upon which relief could be granted, unless their client lied to them too. I’m not saying we should raise Rule 11 yet, but it may be something you may want to consider after discovery.

 

On the “backlash”, my favorite blog is the first that I scanned into this file – note he has the YouTube post embedded into his blog. I also attached the ADC press releases just before the Convention that I found.

 

Mary Jo Provenzano

Paralegal

 

PUCKETT & FARAJ, PC

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

202-280-1039 Fax

 

www.puckettfaraj.com

DC ׀ CA ׀ MI ׀ VA

twitter.com/puckettfaraj

 

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Attachment: ADC ads Jandali. Requests for Admission TO PLAINTIFF.docx
Description: application/vnd.openxmlformats-officedocument.wordprocessingml.document

Attachment: adc facebook backlash.pdf
Description: Adobe PDF document

Attachment: adc press releases.pdf
Description: Adobe PDF document