David,
Dodd has agreed to the settlement you proposed and that we discussed. I am currently out of the country. Iâll be back on the 28th. I expect to have the money in our accounts by then. At that time, I will contact you to complete the settlement.
From: David Shankman [mailto:dshankman@shankmanleone.com]
Sent: Tuesday, December 21, 2010 9:49 AM
To: Haytham
Subject: RE: Audio Visual v. 3D
Where are we on this. Do you still represent Dodd?
David Shankman
Shankman Leone, P.A.
609 E. Jackson St.
Suite 100
Tampa, Florida 33602
Phone (813)223-1099
Facsimile (813) 223-1055
From: Haytham [mailto:haytham@puckettfaraj.com]
Sent: Monday, November 22, 2010 10:55 AM
To: David Shankman
Subject: Re: Audio Visual v. 3D
Hi david,
I'm on the west coast. I'm available at 1 pm your time.
Haytham Faraj
Sent from my iPhone
On Nov 22, 2010, at 7:21 AM, "David Shankman" <dshankman@shankmanleone.com> wrote:
Are you in today?
David Shankman
Shankman Leone, P.A.
609 E. Jackson St.
Suite 100
Tampa, Florida 33602
Phone (813)223-1099
Facsimile (813) 223-1055
<image001.jpg>
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Friday, November 12, 2010 8:38 AM
To: David Shankman
Subject: RE: Audio Visual v. 3D
Good morning David,
Please give me a call when you get a chance this morning, 760-521-7934.
From: David Shankman [mailto:dshankman@shankmanleone.com]
Sent: Thursday, November 11, 2010 11:03 AM
To: Haytham Faraj
Subject: RE: Audio Visual v. 3D
Haytham:
Let me know when you have a second to talk.
Regards,
David Shankman
Shankman Leone, P.A.
609 E. Jackson St.
Suite 100
Tampa, Florida 33602
Phone (813)223-1099
Facsimile (813) 223-1055
<image001.jpg>
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, November 10, 2010 12:00 PM
To: David Shankman
Subject: Audio Visual v. 3D
Dear Mr. Shankman,
My client has requested that I work to settle this matter. 3D Holdings has paid $30,800 thus far of the original $45,000 the parties agreed on. Mr. Dodd is offering to pay a lump sum of $4000, $800.00 in attorneyâs fees and the JAMS costs. At the time of the settlement agreement Mr. Dodd expected the Mr. Colligan would pay half of the amount of the settlement. He paid nothing. Mr. Dodd will pay the amount offered. In return you will agree to release him and 3D holdings. You may continue to pursue Mr. Colligan for any amount that remains outstanding.
Sincerely,
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
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