Abed, Counsel for Jandali and I held a Rule 26 conference On Oct 31, to discuss discovery, scheduling and the preparation of a scheduling conference statement. My approach was non-adversarial to keep doors open for a possible settlement and pitched the Turrath event. They declined the Turrath event unless it also incorporated some of his settlement terms from the first offer. I think there may still be an opportunity to settle but I need to sit with you to understand the parameters that I am allowed to work within. I am available Monday afternoon and can come to your office if you are going to be back. I am also available Tuesday but you will have to come to my office in Alexandria. I am attaching our draft first request for admissions. I have not created interrogatories or noticed a deposition yet because I do not want to engage in full combat to see if we can settle this as quickly as possible. Please review and make recommendations to the request for admissions. I intend to reengage them on settlement talks again this month. If I see that he is being inflexible, I will then notice a deposition and begin to engage in more targeted discovery. I hope you’re enjoying your trip and I look forward to seeing you. Best, Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC 835 Mason Street Suite 150-A Dearborn, MI 48124 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |
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ADC ads Jandali Requests for Admission TO PLAINTIFF.pdf
Description: Adobe PDF document