Hours seem very reasonable. I am going to raise the estimate to 40 hours to make sure we don’t underestimate. I will share the information with the client today and let him decide. You did a very good job on the memo. I appreciate your efforts. Please review it once more. You have a few typographical and syntax errors. I recommend you read it aloud. That’s how I catch mistakes in documents that I no longer see after I’ve been working on them for a long time. Finally, let me know where to send the check. From: Jacqueline Black [mailto:jacquelinerblack@gmail.com] Dear Mr. Faraj: I feel competent to do the motion. As a rough estimate I would say 20-30 hours. This is because I would have to figure out the correct procedure for the motion (ie. is there anything I need to file with the motion, etc) and also I would have to review all transcripts from Mr. Mahfouz's case. If this seems unreasonable, please let me know. When I get a better idea of the logistics involved, I believe I can streamline the process. I also believe that I am capable of drafting a complaint and more than happy to take on the task. Best, Jackie On Mon, Nov 14, 2011 at 7:13 PM, Haytham Faraj <haytham@puckettfaraj.com> wrote: In receipt. Thank you. I’m going to review and get back to you. Do you feel competent to do the motion for relief from judgment? If you feel that you can would you provide me an estimate of the hours you would need to spend on the matter? Do you feel like you are capable of drafting a complaint if I were to provide you with all the facts, an example complaint and access to the applicable law? This is a 1983 matter. Please let me know. From: Jacqueline Black [mailto:jacquelinerblack@gmail.com] Dear Mr. Faraj: Attached please find a memo regarding Mr. Mahfouz's ability to bring a claim. After reviewing the file, it appears that his relief is limited to his ability to file a post-appeal Motion for Relief form Judgment. Provided that he can show (1) his trial counsel failed to inform him of the sex offender registration statute (and he would not have pled had he known of the requirement) and (2) his appellate counsel was ineffective for failing to raise the registration issue, he may have a meritorious claim.We are still within the time frame to file the motion (Michigan does not impose a statute of limitations for a Motion for Relief form Judgment). Please let me know if you have any questions or need any additional information. Thanks, Jackie P.S. I have also attached the Fonville case because it captures Mr. Mahfouz's best chance at winning the motion. On Thu, Nov 10, 2011 at 8:28 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote: Did I send you the log in information to the Michigan handbooks and cle website? If not here it is:
> Dear Mr. Faraj: |