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Re: Jandali v. ADC Request for Admissions



Well done. I think your assessment of the Rule 11 motion is dead on. I have also  contemplated a motion to dismiss from the get go as you know. Perhaps we can still do it. 

Haytham Faraj 
Sent from my iPhone

On Dec 7, 2011, at 3:36 PM, "MaryJo Provenzano" <maryjo1@puckettfaraj.com> wrote:

Haytham:

 

I updated the RFAג€™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 ג€?punishג€? 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 fansג€™ blogs ג€“ 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. Iג€™m not saying we should raise Rule 11 yet, but it may be something you may want to consider after discovery.

 

On the ג€?backlashג€?, my favorite blog is the first that I scanned into this file ג€“ 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

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<ADC ads Jandali. Requests for Admission TO PLAINTIFF.docx>
<adc facebook backlash.pdf>
<adc press releases.pdf>