Thank you Kevin. I appreciate you sharing this. From: Kevin Duff [mailto:kduff@rddlaw.net] Hayham, Yes, we followed up with the ex-wife (Carloyn Cynowa) and ex-girlfriend (Deborah Lawson). We got the docket sheet from his divorce at one point and we have some pleadings. The ex-wife produced documents to us, including records relating to the divorce. Among the documents are some police incident reports, mostly as I recall the ex-wife complaining that she was getting crank calls. There was also an incident where either she or the ex-girlfriend accused him of breaking an entering, but he said he was just retrieving his belongings or something along those lines. None of the incidents ever resulting in charges against anyone. I am also a bit concerned that she may feel there is a financial interest in helping him because last we checked he was still paying her in connection with the divorce. We also got an affidavit from the former girlfriend, which has been produced. She also gave us photos of Cynowa with a crossbow and others of a deer pierced with an arrow hanging in a garage. She’ll say he exhibited violent behavior at times, including once punching through a wall (which I asked him about at his deposition). She told us about the incident where he was holding a gun and there was a dispute with the neighbors (which he testified about at his deposition). She’ll also say that right after his termination he was working the phones, talking to his friends, and talking about retiring once he wins the lawsuit he was planning to bring for defamation. She will also say that she took a call once from Larry Carver who was looking to speak with Cynowa to help him in his case against Lisa. Turns out, however, the ex-girlfriend is a bit of a nut job. He got a restraining order against her as well. He even filed a police complaint against her for stalking him and violating the restraining order at one point – on the same day, and right before, she came to our office for an interview! She spent a night in the county jail relating to this. Of significant concern, however, is that the former girlfriend will get sullied on the stand and will be too much of a side show to help us. We have files on all of this. In case we ultimately decide to call either or both of them at trial, both are disclosed as witnesses. We also attempted to get info from Orbitz, but they were only willing to give standard info – i.e., dates of employment, etc. Kevin From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Gentlemen, I’ve reviewed the Answer to the 2nd amended Complaint and the Motion to Dismiss. I have no recommendation or additions as to substance. There are a few grammatical errors that I am sure will be picked up in the final edit. Every time I dig into this case I start to think about Cynowa’s character. Was there any follow up with any of his ex wives and the young girl who got a restraining order against him. And what about his ex boss at Orbitz and the real reason he was terminated from there? Pardon me for digressing but I thought about these matters after rereading the complaint. Best, Haytham From: John Murray [mailto:jmurray@rddlaw.net] All: Attached please find a draft of our Answer to Plaintiff’s Second Amended Complaint as well as a draft of our motion to dismiss certain counts, which we will file on Friday. Please review the drafts and we’re happy to hear your comments and/or concerns. Ideally we’d appreciate any comments on the draft by tomorrow (Thursday) evening. We will also be getting in touch with Lisa and Bill (either tomorrow or at the latest Friday morning) to get your signed verification for the answer we file. Thanks. Regards, John E. Murray, Esq. Associate Attorney Rachlis Durham Duff Adler & Peel, LLC Phone: (312) 275-0338 Fax: (312) 733-3952 Email: jmurray@rddlaw.net Website: http://www.rddlaw.net RACHLIS This transmission may be: (1) subject to the Attorney-Client Privilege, (2) an attorney work product, or (3) strictly confidential. If you are not the intended recipient of this message, you may not disclose, print, copy or disseminate this information. If you have received this in error, please reply and notify the sender (only) and delete the message. Unauthorized interception of this e-mail is a violation of federal criminal law. |