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3d v. MVM status update



Mike take a look at the language below.  I intend to send this to Rosenblum.  Please let me know what you think or if we need more clarification.  The numbers are just space fillers.  I need you to put in the numbers that you believe are realistically obtainable based on your experience.

 

“There has been no progress since our last session.  We are coming up on a status report date to the judge.  I have a proposal that I believe can help us get to a settlement consistent with the agreement we came to before we last adjourned.  This is based on the assumption that your client continues to intend to cooperate on developing business.  3D Global is a service Disabled Veteran Owned Small Business.  As such it is eligible for certain set aside government contracts that other businesses would not be able to compete for or would face substantial challenges obtaining.  Accordingly, it is our position that 3D can provide to MVM certain opportunities that may not be available otherwise.  3D will agree to conditionally dismiss its law suit in return for MVM depositing $100,000 into an escrow account that shall be released to 3D upon 3D and MVM winning a contract or contracts worth no less than 1.5 million dollars.  If within 18 months of the fund being escrowed, 3D is not able to win a contract using MVM’s capabilities and past performance or cannot present MVM with at least 2 viable contract opportunities, the money will be returned to MVM.  3D must present 2 viable contract opportunities during the 18 months period.  If MVM declines to participate, the funds will transfer to 3D at the conclusion of 18 months.

 

There will be more details to be worked out but I think this captures the essence of our offer.  Please let me know.”

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

1800 Diagonal Road

Suite 210

Alexandria, 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

 

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