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 The information
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