RE: Ramon Davila

[Haytham Faraj <haytham@puckettfaraj.com>]

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. ÂIt 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

 

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