FYI. See below
From: Tabor, Albert [mailto:atabor@velaw.com]
Sent: Friday, October 21, 2011 12:03 AM
To: 'haytham@puckettfaraj.com'
Cc: 'savinbj@mac.com'
Subject: Re: 3d/Savino
Haytham--
Unless Mr. Dodd has returned the $150000 into Brian's Chase account by 5 pm Central time October 28, Brian will no longer accept the proposed solution you and I worked out and will instead seek recovery of all his costs incurred related to this matter, including attorneys' fees and interest at the statutory rate.
I'm rooting for your success in avoiding this.
Bert
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, October 18, 2011 03:45 PM
To: Tabor, Albert
Subject: RE: 3d/Savino
Bert,
I have been in court yesterday and today and did not follow up. I will take it up with Mr. Dodd right away.
From: Tabor, Albert [mailto:atabor@velaw.com]
Sent: Tuesday, October 18, 2011 12:32 PM
To: Haytham Faraj
Subject: RE: 3d/Savino
Haytham,
I am concerned that Mr. Dodd doesn't intend to return Brian's money on a timely basis and that we should be considering other courses for its return, which will add cost and result in Brian's no longer being willing to accept the proposed solution that you and I worked out. To avoid that, I need to know in concrete terms when Brian can expect repayment. Are you in a position to tell me anything?
Thanks,
Bert
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Friday, October 14, 2011 10:48 AM
To: Tabor, Albert
Subject: RE: 3d/Savino
Bert,
I have sent Mr. Dodd. Your email with a recommendation that he accept. I will get back to you as soon as he responds.
From: Tabor, Albert [mailto:atabor@velaw.com]
Sent: Friday, October 14, 2011 11:42 AM
To: Haytham Faraj
Subject: RE: 3d/Savino
Haytham--Here are my suggestions for the release. Let me know what you think. Bert
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Thursday, October 13, 2011 4:12 PM
To: Tabor, Albert
Subject: 3d/Savino
Mr. Tabor,
I am pasting below a paragraph that I request Mr. Savino agree to. I leave it to your discretion whether you would like to modify it so that you can secure Mr. Savinoâs consent. Mr. Dodd has agreed to the language and to refund the $150,000.
â3D Global Solution and Mr. Michael Dodd on the one hand (collectively "Dodd") and Mr. Brian Savino [delete and ] on the other hand ("Savino") hereby mutually agree that Savino's receipt from Dodd by 5 PM CDT on October 14, 2011, of $150,000 into the Chase checking account identified in Savino's email message to Dodd dated September 13, 2011, compromises their claims against one another and release each other, and their respective agents, attorneys, employees, officers, and directors, principals and assigns from any and all claims, demands, causes of action, rights of action or other antagonistic assertions of right, known or unknown, from the beginning of the world until the present, related in any way to the partiesâ business dealings or the transaction between the parties as set forth in the letter between the parties dated July 14, 2011âGood Faith Funding towards 3DGS equity purchaseâ and as set forth in the âPreliminary memorandum of termsâ to purchase equity in 3DGS.â
Regards,
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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