RE: 3D Global Solutions v MVM, Case Number 06-0722

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

Mr. Lewis:
I am available both April 5 and 6 for a call. I am also available all day.  

For the mediation I recommend April 21 for a full day session.  I am also available on the 22nd.

I can be reached directly on my cell phone at 760-521-7934.

I look forward to working with you.

Vr,
Haytham Faraj

-----Original Message-----
From: Lewis, David J. [mailto:dlewis@Sidley.com] 
Sent: Tuesday, March 23, 2010 11:23 AM
To: Haytham Faraj; herbert@hsrlawpc.com
Subject: RE: 3D Global Solutions v MVM, Case Number 06-0722

Counsel

Based on the communications I received this morning, I understand that
Mr. Faraj is in court this week and that Mr. Rosenblum will be out of
town beginning Thursday through next week.  I am going to be out of the
office the week of April 12.  With that in mind, I would like to see if
we can schedule a mediation session (with client representatives) on
either April 8-9 or April 19-23.  I am amenable to scheduling the
mediation for either a half-day (beginning at 9:30 or 1:30) or a full
day (beginning at 10:00), depending on the preferences of the parties.

Please confer with each other by phone or email and let me know by next
Wednesday whether one of those days is acceptable to all concerned.
Additionally, please let me know whether the two of you would be
available for a call (counsel only) on Monday, April 5 or Tuesday, April
6.  I am available from 9:00 a.m. until 7:00 p.m. either day.  Because
Mr. Rosenblum will be out of town, I will ask Mr. Faraj to get back to
me about this scheduling.    

Please keep in mind that Local Rule 84 requires the submission of
Mediation Statements.  If the mediation is scheduled for April 8-9, it
will be acceptable to submit those statements 24 hours in advance.
Otherwise, I would appreciate receiving them at least 48 hours in
advance.  My preference is that the parties exchange the statements with
each other so each is familiar with the other's position.  However,
please also feel free to make a separate submission to me that contains
any additional information that you would like me to maintain in
confidence.  

In preparing the Mediation Statements, you should know that I have
received the complaint, answer and counterclaim and the Court's summary
judgment order, but otherwise know nothing about the dispute except that
there have been prior unsuccessful mediations.  Among other things, I
would be interested in whether you believe those prior mediations have
any bearing on the current negotiations.   

I look forward to working with you.  Please feel free to individually
contact me if you have any questions or if there is anything you think I
should be aware of in terms of how we proceed. 

David J. Lewis
Sidley Austin LLP
202-736-8183
dlewis@sidley.com



 
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