Let’s please begin working on amending the ADC complaint. It is due on the 23rd. I need you to amend it to add additional defenses that we may have missed. I will be communicating with the auto dealers today to get the go ahead on filing the complaint regarding the seized cars. Finally, I would like you to complete and submit the FOIA requests for Mr. Toufeily. I would like the one for Sallaum Lines to be sent from us rather than Sallaum or Mr. Toufeily. He’s concerned that they may go after him. I want you to modify the FOIA requests in a way that suggests that you are looking for information that is part of an investigation. Matters under investigation are exempted from release. Also I would also like you to prepare a FOIA to the Bureau of Immigration and Citizenship Services to obtain information about his petition to become a U.S. citizen. For some reason it has been held up and he is wondering why. Thanks From: MaryJo Provenzano [mailto:maryjo1@puckettfaraj.com] Hatham: I am basically sitting idle now that I am no longer needing to do anything for Debra, other than to upload all electronic files of hers onto DropBox. This is a very slow process because it takes about 20-50mins to upload the larger files. So in the meantime, I am able to work on other things. Please let me know if you have anything that needs doing. Thanks. Mary Jo Provenzano Paralegal PUCKETT & FARAJ, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DC ׀ CA ׀ MI ׀ VA twitter.com/puckettfaraj Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender. |