Mr. Hobbs,
I feared that Mr. Jandali would view the brief notice as a slight. I can assure you that it was not the intent. I believed that the event was in December as I told Steve yesterday before we got on the phone for the conference. Once I reviewed the flyer, I realized that it was only a few days away. I did not mention your offer because I do not have it. Mr. Ayoub, ADC’s legal director, is on his honeymoon. I, therefore, could not discuss the matter with him. In any event, I appreciate you presenting the offer to Mr. Jandali and understand his response. ADC will continue to seek opportunities to resolve the matter. As for discovery, we will comply with all discovery requests that are consistent with the rules and I am sure you will do the same.
I will reengage on settlement negotiation when Mr. Ayoub returns next week.
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.
From: Hobbs, Michael D. [mailto:michael.hobbs@troutmansanders.com]
Sent: Wednesday, November 02, 2011 11:19 AM
To: 'Haytham Faraj'; McNutt, Steve; Khetan, Prashant K.; Gerstein, Jack; Ross, Stu
Cc: 'Mary Jo'
Subject: RE: ADC offer of settlement--Tuurath
Mr. Faraj:
While Mr. Jandali certainly supports the mission of the event, given that it is 8 days from today and considering Mr. Jandali’s schedule, he cannot accept the offer to perform.
In further response to this offer, it needs to be noted that while ADC expresses its desire to resolve this matter:
1) The offer to perform at a event barely a week away, while stated as not offered with disrespect, is difficult to view in any other light;
2) It has made no response to Mr. Jandali’s offer of settlement made nearly 2 months ago.
As we discussed in our phone call yesterday, absent a prompt resolution of this matter, we plan to move forward to serve the ADC with discovery to obtain copies of all internal and external correspondence and related documents regarding the June 2011 ADC National Convention and its unlicensed performance of Mr. Jandali’s work. We trust that you have advised your client regarding its obligations under the federal rules to preserve all electronic and other communications.
Sincerely,
Michael D. Hobbs, Jr.
TROUTMAN SANDERS LLP
600 Peachtree Street
Suite 5200
Atlanta, Georgia 30308-2216
(T) 404.885.3330
(F) 404.962.6588
michael.hobbs@troutmansanders.com
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, November 01, 2011 4:26 PM
To: McNutt, Steve; Hobbs, Michael D.; Khetan, Prashant K.; Gerstein, Jack; Ross, Stu
Cc: 'Mary Jo'
Subject: ADC offer of settlement--Tuurath
Gentlemen,
Given the short time that remains before this event. I wanted to get this information to you as quickly as possible. I hope no intent to disrespect Mr. Jandali is imputed to the late notice of this event. It simply was not considered as a possible opportunity until recently.
ADC wishes to settle this matter and would like to renew its friendship and goodwill to Mr. Jandali. I have, therefore, been asked to inquire whether Mr. Jandali would accept an invitation to perform at a ADC event celebrating Arab culture. ADC believes this would be an excellent event to make amends because this is an event specifically intended to celebrate culture which would perfectly encompass Mr. Jandali’s music.
The offer would include a portion of the proceeds going to a charity of Mr. Jandali’s choosing and in his name. Please see more about the event below.
Sincerely,
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.
|
From: McNutt, Steve [mailto:Steven.McNutt@troutmansanders.com]
Sent: Tuesday, November 01, 2011 9:55 AM
To: Haytham@puckettfaraj.com
Cc: Hobbs, Michael D.; Khetan, Prashant K.; Gerstein, Jack; Ross, Stu
Subject: Jandali: Call
Mr. Faraj:
I write to confirm our call at 3:00 p.m. today, as we just discussed. Please use the following call in number (877) 506-4272; passcode (202) 662-2069.
Regards,
Steve
Steven W. McNutt
Troutman Sanders, LLP
401 9th Street, NW
Suite 1000
Washington, DC 20004-2134
Direct Dial: 202.662.2069
Phone: 202.274.2950
Facsimile: 202.654.5833
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