If she sues you we would simply handle it as part of the process of the law suit so there would be no cost to you unless we collect. From: jim rowe [mailto:jroweusmc@yahoo.com] Sent: Tuesday, January 03, 2012 9:16 AM To: Haytham Faraj Subject: Re: Civil Suit against the Klay's One more question. In the event that she sues me, would you defend me, and what would it cost? My concern is obviously shelling out more money and possibly having a net loss, when to be honest I have a pretty unstable employment situation right now.
From: Haytham Faraj <haytham@puckettfaraj.com> To: 'jim rowe' <jroweusmc@yahoo.com> Sent: Monday, January 2, 2012 1:39 PM Subject: RE: Civil Suit against the Klay's I have provided answers to your questions below. From: jim rowe [mailto:jroweusmc@yahoo.com] Sent: Friday, December 30, 2011 8:31 AM To: Haytham Faraj Subject: Civil Suit against the Klay's Questions before we move forward. 1. Does this open me up to a potential counter-suit from them against me? She can of course sue you or countersue you. A common tactic by lawyers is to sometimes countersue to scare you. If I were to guess, I would say that this is a possibility. She has no chance of success. A law suit would expose her to all the things that we were prohibited from bringing up in the criminal trial. 2. What kind of a time commitment will this take on my end? Maigen's major concern is that this will be a huge stressor and it will take up a lot of our time. There is not much of a time commitment. You will have to be deposed. It would be under oath and transcribed. It will not take time from you except that you may be required to speak to me a few times during the court of the law suit. 3. Will this be settled in a matter of months or years? I anticipate it will take 12-16 months from start to finish. 4. How realistic is it that we win and what would be a reasonable amount of payment to expect? I give our chances of prevailing a 90% likelihood.
From: Haytham Faraj <haytham@puckettfaraj.com> To: Shinn Capt Scott R <scott.shinn@usmc.mil> Cc: jim rowe <jroweusmc@yahoo.com> Sent: Tuesday, December 27, 2011 2:49 PM Subject: Re: From Jim Rowe
Jim. I'm glad to see you're out and that you got to spend Christmas at home. I'm ready to file when you say go. Once you let me know, I will send you a retainer agreement, all I'll need is your signature. You don't have to pay up front for this one. I collect when you collect.
Haytham Faraj Sent from my iPhone
On Dec 27, 2011, at 3:37 PM, "Shinn Capt Scott R" <scott.shinn@usmc.mil> wrote:
> Jim, > I'm glad I was able to assist. Whatever the consequences are following this, I'm sure you can handle them in stride and hit the ground running. Right now, concentrate on Maigen, your family, and work. The rest will sort itself out in time. > > > S/F > ~Russ > > > S. Russell Shinn > Captain, US Marine Corps > > Officer-in-Charge > Defense Counsel Assistance Program > Marine Corps Defense Services Organization > > Mailing Address: > Defense Counsel Assistance Program (HQMC, JA/D) > 755 S. Courthouse Road, Ste. 1000 > Arlington, VA 22204-2482 > 703.604.0574 (w) > 703.470.0671 (c) > > "Marines Defending Marines" > > ATTORNEY-CLIENT PRIVILEGED COMMUNICATION OR ATTORNEY WORK PRODUCT. The information contained in or attached to this communication is confidential, legally privileged and intended for use only by the individual or entity to which it is transmitted. Any other use of this communication is strictly prohibited. Do not disseminate without the approval of the OIC, DCAP. This e-mail and all other electronic or voice communication from this address are for informational purposes only. No such communication is intended by the sender or the agency to constitute either an electronic record, or an electronic signature, or to constitute any agreement by the sender to conduct a transaction by electronic means. If you receive this e-mail in error, please permanently delete the original and any other copies or printouts of this e-mail, and notify me immediately at the above e-mail address or phone number. To the extent the information contained in or attached to this communication contains Privacy Act information, that information is for OFFICIAL USE ONLY. > > > > -----Original Message----- > From: jim rowe [mailto:jroweusmc@yahoo.com] > Sent: Tuesday, December 27, 2011 14:23 > To: Haytham Faraj; Shinn Capt Scott R > Subject: From Jim Rowe > > Gentlemen, > > I want to thank you again for all your hard work in helping me get out of the mess I got myself in. I am sorry for making it more difficult on everyone with my explosive performance on the stand. I know you both gave me wise counsel, yet I let the emotion and frustration of this all coming to an end come out while speaking. Again, sorry about that. > > Russ- not sure if I need to do anything else, just let me know. Not sure if they will try to PCS me or just wait on a BOI. > > Mr. Faraj- hope to talk to you when it is convenient on what a suit against Ariana and Ben Klay would look like. > > Thanks again, > > Jim |