Hi Ellen, Weâve considered the plea offer. Mr. Davila simply cannot plead guilty to any criminal misconduct as a result of any intentional misrepresentation. At worst, he may have some benign errors in reporting. He cannot admit to ever reporting having met someone when he did not or any other material misrepresentation. I recognize that this email constitutes a rejection of your offer. I attempted to find a petty offense that could encapsulate the facts as we know them to be in the hope that I can make a counter-offer. Unfortunately, I did not. This isnât about the exposure to punishment. It is about Mr. Davilaâs ability to stand in front of a judge and admit to things that did not happen. We worked on developing the facts to try and find a compromise but could not fit the charges into the facts as we know them to be. Best regards, Haytham From: Chubin Epstein, Ellen (USADC) [mailto:Ellen.Chubin@usdoj.gov] Sent: Friday, June 03, 2011 2:25 PM To: Haytham Faraj Subject: RE: Ramon Davila Thanks for letting me know, Haytham. Enjoy your weekend, too. Ellen From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Friday, June 03, 2011 2:04 PM To: Chubin Epstein, Ellen (USADC) Subject: Re: Ramon Davila Ellen, My Michigan address has changed. My new address is: 22167 Morley Ave. Dearborn, MI 48124. Have a good weekend. Haytham Sent from my iPad On Jun 2, 2011, at 7:12 PM, "Chubin Epstein, Ellen (USADC)" <Ellen.Chubin@usdoj.gov> wrote: Hi, Haytham. I hope this email finds you well. Iâve been back from maternity leave for a few months now, and I have been turning my attention once again to Mr. Davilaâs false representations in reports of background investigations. Although you previously indicated that your client was not interested in a guilty plea, I wanted to let you know that the government is still willing to resolve this matter prior to indictment, in order to avoid a potential trial and the associated expenditure of government resources. Accordingly, I am attaching a pre-indictment plea offer, which will expire on June 17, 2011. In this plea offer, the government agrees to allocute for a sentence just below the bottom of the applicable Guideline range. If this offer is rejected, any future plea deal will not be nearly as generous to your client. Please feel free to call me if you have any questions. Ellen Ellen Chubin Epstein Assistant U.S. Attorney for D.C. Fraud & Public Corruption Section 555 Fourth Street, NW Room 5255 Washington, DC 20530 (202) 252-7861 (office) (202) 307-2304 (fax) (202) 471-0670 (Blackberry) From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Monday, July 12, 2010 4:40 PM To: Chubin Epstein, Ellen (USADC) Subject: Ramon Davila Dear Ms. Chubin-Epstein: Mr. Davila has considered your offer of pleading guilty to charges of falsifying records or statements. He declines your offer. Vr, Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexndria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. <SCN_20110602184808_001.pdf>
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