RE: Goodfellas v. Macys

["Haytham Faraj" <haytham@puckettfaraj.com>]

Carolynn:
If these people do not want to cooperate, I recommend you state so in the
motion.  Give a brief summary of their relevant testimony based on
information that we have regardless of where it came from.  The argument
should be that these we have a good faith reason to believe that they will
testify to the following facts (whatever their respective factual testimony
will be).  You can that argument with facts related to their existing
business interest with Macy's and why they are reluctant to cooperate.
Their reluctance to cooperate will be overcome by a subpoena that will force
them to come to court and testify.  It is then up to the fact finder to
decide the weight to give their testimony even if it not favorable to
Goodfellas.  

-----Original Message-----
From: Carolynn Beck [mailto:carolynnn@gmail.com] 
Sent: Wednesday, May 19, 2010 12:28 PM
To: goodfellaswear@aol.com
Cc: Haytham Faraj
Subject: Goodfellas v. Macys

Hi Wissam,

Thanks for your time on the phone today. I really appreciate it. Like  
I promised you, I'm sending you some notes from our discussion of  
people/companies to contact regarding affidavits or statements, so you  
can check things off as you make calls and contact people. Also, if  
there are any people you want Haytham or I to try and contact, let us  
know via email.

1.  Coogi: Trevor Clark. Statements from Pam and Bruce re contact from  
Macy's
2. Cheryl McGowan, the sales rep at Sean John re Macy's contacting the  
company and causing the company to stop selling to Goodfellas.
3. Greg McGowan at Academiks re same
4. Any contacts (Carolyn Steinberg?) at CIT stating that they stopped  
approving orders because of Macy's claiming that Goodfellas was  
selling counterfeit
5. Same for Wells Fargo
6. Name and number of Macy's customer service rep who told you that  
Macy's felt threatened by Goodfellas due to all the returns
7. Big Greg or other Wayne County Sheriff statements
8. Damages caused by the loss of business from different companies due  
to Macy's actions.

Please let me know if you think of anything else I should know about,  
or if you have any questions. I look forward to hearing back from you.

Carolynn