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Assistance with a civil case; 3D global v. MVM



Hi Cyrena,

You may recall me telling you about a case that I was going to be trying this year.  The trial date is set for March 14.  The trial is going to be in the U.S. District Court for the District of Columbia.  You may do as much or as little as you like.  If you plan to sit in court with me I need you to review Rule 83.4 of the local rules see here http://www.dcd.uscourts.gov/dcd/sites/dcd/files/2010_MARCH_LOCAL_RULES.pdf.  If you wish to participate I need you to get permission from the Dean pursuant to Local Rule 83.4(b)(1).  If you don’t qualify, under the rules, I can still have you participate in ways that you will find interesting and fun.

 

The case is a dispute between two contractors regarding a breach of contract claim.  I am attaching for you to read the pretrial statement, the amended complaint, the court decision on a motion for summary judgment and the contracts that form the basis for of the dispute.  These will give you a general overview of the case and the legal issues at stake.  Please review them and call me to discuss questions you may have.  Start with the pretrial statement and go on to review the rest.  I think that will provide you the best overview.

 

Here’s our first task:

 

On March 9, 2011, I plan to conduct a focus group/mock trial to test the strength of our position.  I would normally do this a lot earlier than the week before but my time is very limited. Below are the coordinating instructions to put this together if you’re interested in participating.  If you cannot participate please let me know as soon as possible so I can find people for the mock trial. 

 

1.        Finding 5-7 law students who are interested in playing a mock jury.  They will benefit from learning how to put a focus group for a trial together.  The total time we need them is 4 hours.

2.       Location: We can do it in our office in Alexandria. It is literally right across from the King Street Metro.  Alternatively, we can do it at the school but we would need a room, preferably one of the courtrooms. I have no objection to having a larger audience if more people would like to participate.

3.       Time:  We can do it at anytime.  Evening is possible if it is more convenient.  I propose starting anytime between 10 am and 6 pm.

4.       We will provide a meal and refreshments for the participants as well as a transportation credit.

5.       Participants will participate by listening to a presentation of the evidence and reviewing some exhibits.  We will then engage in a sociometric exercise to test different theories. 

6.       It is critical that the participants have no idea who our firm represents.  Studies have shown that focus group participants will favor the side that is sponsoring the session.

 

I’m looking forward to working with you.

 

 

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

P.O. Box 1016

Dearborn Heights, MI 48127

313-457-1390 Phone

202-280-1039 Fax

 

 

www.puckettfaraj.com

 

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.

 

Attachment: 3D Global v. MVM pretrial statement final.pdf
Description: Adobe PDF document

Attachment: 19-main.pdf
Description: Adobe PDF document

Attachment: Decision on Motion for summary judgement.doc
Description: MS-Word document

Attachment: Kabul agreement 090529.pdf
Description: Adobe PDF document

Attachment: Kabul Agreement and TO 1.pdf
Description: Adobe PDF document

Attachment: Kabul TO#2.pdf
Description: Adobe PDF document