RE: Disclosures ADC

["Haytham Faraj" <Haytham@puckettfaraj.com>]

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