RE: (Cynowa v. CSSS et al.) Plaintiff's Response Brief in Opposition to Defendants' Motion for Summary Judgment

[Haytham Faraj <haytham@puckettfaraj.com>]

In receipt.   Thank you.  I will review all of this and will be discussing
it with you when we meet. I am about to enter my third week of a jury trial
that was supposed to end early this week, hence my radio silence on the net.

-----Original Message-----
From: William F. Slater, III [mailto:slater@billslater.com] 
Sent: Wednesday, March 02, 2011 8:03 PM
To: Kevin Duff
Cc: slater@billslater.com; 'Haytham'; 'John Murray'
Subject: RE: (Cynowa v. CSSS et al.) Plaintiff's Response Brief in
Opposition to Defendants' Motion for Summary Judgment

Kevin,

Thanks and I understand.

For Haytham's benefit, I have attached the document I reference.

By the way, it could be VERY useful for you to know that Larry Carver called
me while I was writing this document.  His personal instructions: 
"Pull out all the stops and BURY Nikiforis with everything you can add to
the document."  So I did.

Best regards,

Bill
William F. Slater, III, PMP
Chicago, IL
United States of America
slater@billslater.com
http://billslater.com
http://billslater.com/career
773 - 235 - 3080 - Home
312 - 758 - 0307 - Mobile


On Wed, March 2, 2011 6:29 pm, Kevin Duff wrote:
> Bill,
>
> Thanks for your email.  The focus for the summary judgment motion is 
> as we laid it out in our initial filing on January 19.  While the 
> manner in we you were treated may be helpful to understanding the 
> context of the events at issue as we prepare for trial, we do not want 
> to interject new material into the summary judgment analysis because 
> we do not want the Court to conclude that there is a dispute over the 
> facts that a jury must decide.
>
> I would be happy to discuss this with you tomorrow if you would like 
> to give me a call.
>
> Kevin
>
> -----Original Message-----
> From: William F. Slater, III [mailto:slater@billslater.com]
> Sent: Wednesday, March 02, 2011 6:12 PM
> To: John Murray
> Cc: kduff@rddlaw.net; 'Haytham'
> Subject: Re: (Cynowa v. CSSS et al.) Plaintiff's Response Brief in 
> Opposition to Defendants' Motion for Summary Judgment
>
> John,
>
> I have tried to explain in earlier occasions is that the things that 
> transpired up to and since the termination of Cynowa were a form of 
> "Workplace Mobbing."  (Them against me)
>
> http://www.mobbing-usa.com/
>
> Cynowa's behavior that led to his termination was his attempt to 
> establish himself as the leader of the gang there.  And also to show 
> that he had contempt for CSSS because the previous Program Manager, 
> Larry McKeehan, who was Chris' good buddy, was fired.
>
> It would be very instructive if you could gather evidence in the form 
> of e-mails, documents, and depositions, etc. that would show how much 
> I was hated, and subsequently trashed by these people.  Also go back 
> and look at the e-mails that I listed in the Appendix of my March 2007 
> 72-page response to CSSS regarding Nikoforis' Employee Dispute 
> Resolution against me.  These are e-mails written by the next 
> self-appointed leader of the gang there.  He wanted to have me kicked 
> out in retaliation for the fact that Cynowa was fired.
>
> Anyway, you folks need to see what is really going on here and how 
> Cynowa (and Carver) are using the legal system to finish what they 
> could not accomplish as a mob in the workplace.
>
> Thanks,
>
> Best regards,
>
> William F. Slater, III, PMP
> Chicago, IL
> United States of America
> slater@billslater.com
> http://billslater.com
> http://billslater.com/career
> 773 - 235 - 3080 - Home
> 312 - 758 - 0307 - Mobile
>
>
>
> On Wed, March 2, 2011 4:32 pm, John Murray wrote:
>> All:
>>
>>
>>
>> Attached please find a copy of the Plaintiff's Response Brief in 
>> Opposition to Defendants' Motion for Summary Judgment.  We will begin 
>> on our reply brief in short order.  Please see attached.
>>
>>
>>
>>
>>
>> Regards,
>>
>>
>>
>> John E. Murray, Esq.
>>
>> Associate Attorney
>>
>> Rachlis Durham Duff & Adler, LLC
>>
>> 542 South Dearborn Street, Suite 900
>>
>> Chicago, IL 60605
>>
>> Office: (312) 733-3950
>>
>> Direct: (312) 275-0338
>>
>> Mobile: (810) 824-7197
>>
>> Fax: (312) 733-3952
>>
>> Email: jmurray@rddlaw.net
>>
>> Firm website: www.rddlaw.net
>>
>>
>>
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