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Re: Assistance with a civil case; 3D global v. MVM



I did. Sorry. I'm in trial and swamped. 

Haytham Faraj 
Sent from my iPhone

On Feb 24, 2011, at 5:09 PM, Cyrena Khoury <cyrenakhoury@gmail.com> wrote:

Haytham,
Just checking -- did you get my email below?
Cyrena

On Sun, Feb 20, 2011 at 7:32 PM, Cyrena Khoury <cyrenakhoury@gmail.com> wrote:
Hi Haytham,
Good to hear from you - thanks for thinking of me for this!

To be frank, although I'm happy to do what I can to help, I think we
are really unlikely to find 5-7 WCL students who are around and
willing to commit to this on the 9th. That date falls smack in the
middle of WCL's spring break. Given this, as well as my schedule over
the next couple weeks (crazy), I would suggest tapping another
resource first, and then coming back to me if that doesn't work out.
At that point, I'll send an email around and see if anyone is
interested and in town.

Wish I had better news! I'm in Nicaragua til early Tues (with no
Internet tomo). Let me know if the plan I laid out above works for
you, and then we can touch base on Tues or Weds by phone if you want.

Take care,

Cyrena

Cyrena Khoury
+1 (202) 316-2462

On Feb 19, 2011, at 12:30, Haytham Faraj <haytham@puckettfaraj.com> wrote:

> Hi Cyrena,
>
> You may recall me telling you about a case that I was going to be trying
> this year.  The trial date is set for March 14.  The trial is going to be in
> the U.S. District Court for the District of Columbia.  You may do as much or
> as little as you like.  If you plan to sit in court with me I need you to
> review Rule 83.4 of the local rules see here
> http://www.dcd.uscourts.gov/dcd/sites/dcd/files/2010_MARCH_LOCAL_RULES.pdf.
> If you wish to participate I need you to get permission from the Dean
> pursuant to Local Rule 83.4(b)(1).  If you don't qualify, under the rules, I
> can still have you participate in ways that you will find interesting and
> fun.
>
>
>
> The case is a dispute between two contractors regarding a breach of contract
> claim.  I am attaching for you to read the pretrial statement, the amended
> complaint, the court decision on a motion for summary judgment and the
> contracts that form the basis for of the dispute.  These will give you a
> general overview of the case and the legal issues at stake.  Please review
> them and call me to discuss questions you may have.  Start with the pretrial
> statement and go on to review the rest.  I think that will provide you the
> best overview.
>
>
>
> Here's our first task:
>
>
>
> On March 9, 2011, I plan to conduct a focus group/mock trial to test the
> strength of our position.  I would normally do this a lot earlier than the
> week before but my time is very limited. Below are the coordinating
> instructions to put this together if you're interested in participating.  If
> you cannot participate please let me know as soon as possible so I can find
> people for the mock trial.
>
>
>
> 1.        Finding 5-7 law students who are interested in playing a mock
> jury.  They will benefit from learning how to put a focus group for a trial
> together.  The total time we need them is 4 hours.
>
> 2.       Location: We can do it in our office in Alexandria. It is literally
> right across from the King Street Metro.  Alternatively, we can do it at the
> school but we would need a room, preferably one of the courtrooms. I have no
> objection to having a larger audience if more people would like to
> participate.
>
> 3.       Time:  We can do it at anytime.  Evening is possible if it is more
> convenient.  I propose starting anytime between 10 am and 6 pm.
>
> 4.       We will provide a meal and refreshments for the participants as
> well as a transportation credit.
>
> 5.       Participants will participate by listening to a presentation of the
> evidence and reviewing some exhibits.  We will then engage in a sociometric
> exercise to test different theories.
>
> 6.       It is critical that the participants have no idea who our firm
> represents.  Studies have shown that focus group participants will favor the
> side that is sponsoring the session.
>
>
>
> I'm looking forward to working with you.
>
>
>
>
>
> 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
>
>
>
>
>
> <http://www.puckettfaraj.com/> 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
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>
>
>
> <3D Global v. MVM pretrial statement final.pdf>
> <19-main.pdf>
> <Decision on Motion for summary judgement.doc>
> <Kabul agreement 090529.pdf>
> <Kabul Agreement and TO 1.pdf>
> <Kabul TO#2.pdf>



--
Cyrena Khoury
JD candidate 2012
American University Washington College of Law
cyrenakhoury@gmail.com
+1 (202) 316-2462