RE: Goodfellas v. Macy's

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

I'll be back in Detroit tomorrow evening.  I'll grab the file and see what's
useful.  I'll give you a call Saturday to discuss.

-----Original Message-----
From: Carolynn Beck [mailto:carolynnn@gmail.com] 
Sent: Thursday, April 29, 2010 4:04 PM
To: Haytham Faraj
Subject: Fwd: Goodfellas v. Macy's

Haytham,

I asked Mr. Aoun to make copies of the files and send them to me. I  
will probably only need a few files out of the box to use as evidence  
to refute Macy's claims in their summary disposition motion, but I  
didn't want to have the client go through and try to find the useful  
stuff, since he may not know what to look for. Let me know if you  
think there's a better way to do it - I felt a little bad asking the  
client to make the copies of thousands of pages but wasn't sure what  
other way there was and thought he should hang onto the originals  
since you live closer to him and will want the files yourself. I can  
also try to call Mr. Hall to see if he has anything scanned into his  
computer but wanted to check in with you first.

Thanks,

Carolynn

Begin forwarded message:

From: Carolynn Beck <carolynn.beck@gmail.com>
Date: April 29, 2010 3:59:39 PM EDT
To: Make Dat Doe gfella <gfwear@hotmail.com>
Cc: goodfellaswear@aol.com
Subject: Re: Goodfellas v. Macy's

Sam,

Please make copies of the files and UPS the copies to me at:

Carolynn Beck
8190 Strawberry Lane,
Apt 322
Falls Church, VA 22042

As I had mentioned on the phone, I don't want to risk the originals  
getting lost, so I want you to hang onto those until Haytham is back  
in town. He will undoubtedly want them for his own records.

I had also wanted to ask you the following over the phone, but please  
take some time to think it through and call me or email me back with  
the answers when you have a moment:

1. Do you have copies of depositions of you and Virginia Smith, the  
warrant, and any other depositions or other evidence/testimony  
regarding the damage to your merchandise and damage to your business  
relationships with other merchants? ***This may be in the box you got  
from Cyril Hall, but are the main things I am going to be searching  
for if you do send the files over. If you don't know where they are, I  
will just search for them once I receive the box. If you do have them,  
or think Mr. Hall may already have scanned copies of them in his  
computer, please let me know and I can call Mr. Hall to see if he will  
send them to me.***

2. How much of your merchandise couldn't be sold as a result of the  
seizure of your goods? How much of it had to be marked down? What is  
your estimated loss in sales as a result of having to close shop (if  
you had to close shop?)

3. How much of your merchandise was damaged and couldn't be sold as a  
result of their being seized and then returned (anything that I can  
use to refute Macy's reference to Virginia Smith's deposition stating  
that most all of the merchandise that was returned to you was sold)?

4. How much time was there between seizure of the 70 boxes of  
clothing, and their return? What items were identified as stolen?  
(Your complaint states that Macys was only looking to seize two items  
of clothing, and took 70 boxes, but Macy's summary disposition motion  
states that 29 items of clothing were identified as stolen, and the  
rest were returned to you in sellable condition).

5. Did you directly observe or know of anyone who directly observed or  
heard Macy's contacting your vendors, and can testify as to what  
Macy's said to your vendors (What did they say?)

6. Were these business relationships damaged, and in what way? Did any  
vendors cancel or change their contracts with you in any way?

7. Did you or anyone you know directly observe/hear about Macy's  
intent to seize your merchandise, or ruin your business? I need names,  
and things that you heard directly from Macy's, or someone affiliated  
with Macy's that told you these things, and what they said, and how  
they know it.

8. What did "Big Greg" say to you regarding the investigation? Did he  
observe or hear anything directly from Macy's management, Macy's  
employees, or otherwise that can help support our claims?

9. Did you or anyone you know directly hear or observe anything that  
can help us prove that Macy's had the intent to interfere with your  
business relationships? We need proof of affirmative acts by Macy's,  
even if it's just testimony from someone who knows directly that  
Macy's had this intent, and did things specifically for that purpose,  
even if it was under the guise of a lawful investigation.

10. What might help us with the above is if you have any evidence that  
Macy's contacted the vendors before the investigation was ordered by  
the court, and said anything improper, or if you have anyone who  
observed or heard Macy's saying something about their improper purposes.

If you already answered some of these questions in the deposition,  
please let me know. I will see it when I receive it, but it will be  
helpful to know ahead of time so I know what's already been entered  
into the record.

Thank you,

Carolynn Beck
(202) 316-1367



On Apr 29, 2010, at 3:32 PM, Make Dat Doe gfella wrote:



From: gfwear@hotmail.com
To: goodfellaswear@aol.com
Subject: RE: Goodfellas v. Macy's
Date: Thu, 29 Apr 2010 14:33:49 -0400

Hi Carolynn,

Sorry I cant scan them, there are thousands of pages.But if u can  
please give me an address and I can ship it to you UPS next day.

Thanks

Sam

 > Subject: Fw: Goodfellas v. Macy's
 > To: gfwear@hotmail.com
 > From: goodfellaswear@aol.com
 > Date: Thu, 29 Apr 2010 18:31:24 +0000
 >
 >
 > Sent from my Verizon Wireless BlackBerry
 >
 > -----Original Message-----
 > From: Carolynn Beck <carolynn.beck@gmail.com>
 > Date: Thu, 29 Apr 2010 13:30:02
 > To: <goodfellaswear@aol.com>
 > Subject: Re: Goodfellas v. Macy's
 >
 > Hi Wissam,
 >
 > That's great, thanks for picking that up. Will you still be able to
 > scan and send the documents? If you would prefer, you could have
 > copies of the documents made and UPS them to me by tomorrow or  
Monday.
 > I just don't want to risk the originals getting lost on the way to  
me,
 > so I think you should hang onto the originals until Haytham is back  
in
 > Michigan and can pick them up from you.
 >
 > Please let me know what would be most convenient, and what you can do
 > and I will let you know the address to have the documents sent to.
 >
 > Thanks,
 >
 > Carolynn Beck
 > (202) 316-1367
 >
 >
 >
 > On Apr 29, 2010, at 1:09 PM, goodfellaswear@aol.com wrote:
 >
 > I just picked it up and it is a big box
 > Sent from my Verizon Wireless BlackBerry
 >
 > From: Carolynn Beck <carolynn.beck@gmail.com>
 > Date: Wed, 28 Apr 2010 11:34:32 -0400
 > To: <goodfellaswear@aol.com>
 > Subject: Re: Goodfellas v. Macy's
 >
 > Hi Wissam,
 >
 > That's great to hear. Have you heard back from them yet regarding  
your
 > file?
 >
 > Thanks,
 >
 > Carolynn
 >
 >
 > > On Apr 27, 2010 4:27 PM, <goodfellaswear@aol.com> wrote:
 > >
 > > Hi Carolynn,
 > > I spoke to Cyrill Hall's assistant about my file. She said that  
they
 > > should be ready Wednesday.
 > > Thank you
 > >
 > >
 > > Wissam Aoun
 > >
 > >
 > >
 > > -----Original Message-----
 > > From: Carolynn Beck <carolynn.beck@gmail.com>
 > > To: goodfellaswear@aol.co...
 > >
 >
 >

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