Good morning Herb, I have been speaking to Mike about terms for a settlement. He is still at $85k but I believe I can convince him to come down from the minimum amount he is demanding. Last time you and I spoke you believed you could bring your client up to $30k. I believe I can bring Mike down from $85k to $50k. That would split the difference between us. I know I can convince him to accept monthly payments from your client and to agree to refund at least a portion of the settlement amount if they can do business. Let me caveat this by saying I have not spoken to him about this amount. I only believe that I can persuade him. I know, however, that he was agreeable to payments, doing business and refunding the money either in lump sum or payments depending on the value of the contract. These are things that I believe we can work out. I hope you can speak to your client to persuade him. I would like to inform the judge on Monday or earlier that we have an agreed to settlement. The difference between $30k and $50k is not very much. And as you said, and I agreed, that the costs to both parties merits not going to trial. On another matter, I’m looking for a local Alexandria firm to start a matter for me to have the Alexandria court issue a foreign subpoena for a deposition from an Illinois court. Do you know anyone that can do that or are you able to do it? If you can do it, please tell me what you need from the Illinois court and the fees. Best, Haytham Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC P.O. Box 1016 Dearborn Heights, MI 48127 313-457-1390 Phone 202-280-1039 Fax 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. |