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.