A case file is on its way to you. The case name is Mahfouz. Please let me know if you need access to a research website that includes Michigan laws and cases. What I want you from you is memorandum of law that answers the following questions: 1. Whether the late filing of the appeal by the appellate counsel resulted in prejudice to the substance of the case? What I mean by that is was the late filing harmless error or was malpractice committed by the late filing that prejudiced the client’s opportunity to have his guilty plea set aside? 2. Whether a claim for ineffective assistance of counsel lies against defense trial counsel for failing to advise the client that he would have to register as a sex offender? 3. Whether the plea can be set aside upon a showing that trial defense counsel coerced his client into pleading guilty? 4. Whether Michigan law allows a guilty plea to be set aside for any reason? 5. Whether we are still within the window of opportunity to file such a claim if Michigan law allows it? Please manage your time to spend no more than 12 hours on answering these questions. The rate for the work is $50 per hour. If you find that based on the status of the law in Michigan we can make a good faith challenge to the guilty plea to withdraw it or set it aside, I will engage the client to fund the additional work. Thank you From: Jacqueline Black [mailto:jacquelinerblack@gmail.com] Sorry for the delay: Jacqueline Black 4908 Cape May Avenue On Mon, Oct 24, 2011 at 7:53 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote: Hi Jackie, Please send me your mailing address. From: Jacqueline Black [mailto:jacquelinerblack@gmail.com] Dear Mr. Faraj: I just wanted to check in, I'm sure you had a lot to catch up on after your vacation. I'd be happy to assist you with the motion (or any other projects you may need assistance with) at your convenience. Best, Jackie On Mon, Aug 15, 2011 at 7:13 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote: Yes. I will. I'll call Wednesday after I meet with the client. Haytham Faraj Sent from my iPhone
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