Re: Disclosures ADC

[Haytham Faraj <haytham@puckettfaraj.com>]

Agree with both comments let me review and get back to you. 

Haytham Faraj 
Sent from my iPhone

On Dec 8, 2011, at 2:05 PM, "MaryJo Provenzano" <maryjo1@puckettfaraj.com> wrote:

> Haytham:  I did some additional editing. I thought it said too much and so I
> trimmed it down some.  I have put two questions in yellow highlighting.  One
> - We were given the Chairman's home phone number and it seems like it would
> not be a good idea to give that number out since there was a lot of
> animosity toward the Chair.  Do you agree?
> Also, I think that Abed Ayoub should not be listed as a witness since he was
> providing legal advice and should be covered by attorney client privilege.
> Do you agree?
> 
> Mary Jo Provenzano
> Paralegal
> 
> PUCKETT & FARAJ, PC
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> 
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> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Thursday, December 08, 2011 10:03 AM
> To: 'MaryJo Provenzano'
> Subject: RE: Disclosures ADC
> 
> Mary Jo,
> Please review the initial disclosures for ADC.  There are a number of
> grammatical and syntax mistakes.  I was trying to edit but in some instances
> the it is not very clear what the intent is.  I do not want to make edits
> that change the meaning of what is intended.
> 
> -----Original Message-----
> From: MaryJo Provenzano [mailto:maryjo1@puckettfaraj.com] 
> Sent: Wednesday, December 07, 2011 11:22 AM
> To: 'Haytham Faraj'
> Subject: RE: Disclosures ADC
> 
> Haytham:
> 
> I have edited the disclosures a bit, in an effort not to say too much.
> However, here they are completed.  Please let me know if you agree with the
> stuff I cut out.  I can filed this for you - are you coming back in today or
> are you gone?  If you're gone, I need to figure out how to get your
> electronic signature to paste onto the document. 
> I will work on the Requests for Admissions and Amended Answer and send those
> to you later. I'm not sure I agree with you on the laches thing. Thanks.
> 
> 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
> 
> 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.
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Wednesday, December 07, 2011 6:58 AM
> To: 'MaryJo Provenzano'
> Subject: FW: Disclosures
> 
> Hi Mary Jo,
> Please use the attached to prepare the disclosures.  I think once you review
> this information you will find additional matters to put in the discovery
> requests.  For example, a request for admission that Jandali personally saw
> or learned that the ADC website included his YouTube video but that he did
> not object.  I also think we may need to amend our answer to include laches.
> 
> -----Original Message-----
> From: Abed Ayoub [mailto:abedayoub@gmail.com]
> Sent: Wednesday, December 07, 2011 3:49 AM
> To: Haytham Faraj
> Subject: Disclosures
> 
> Haytham,
> 
> Attached you will find the disclosure request, along with an additional
> document with some of the information.  Most of the material is attached.  I
> am working on getting together the rest of the facebook postings -- and any
> additional details from those involved with the matter. I will print out a
> copy and bring it with me tomorrow.
> 
> See you in the morning,
> 
> Abed
> 
> <Initial Disclosure- Defendant.rtf>