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RE: 3D Global Solutions v MVM



Dear Mr. Lewis:

I have attached 2 full employee files.  These are typical of the files that were prepared on each TCN recruited by 3DGS for MVM.  I also took the liberty of attaching the correspondence from MVM’s former counsel setting forth MVM’s legal position to the Department of state as well as their final settlement agreement. 

 

In response to Mr. Rosenblum’s letter which I have included below, I have numbered my paragraphs to correspond to Mr. Rosenblum’s letter:

 

Paragraph 2:  ALTA is not certified by the State Department to conduct testing.  They are a self certified company that attempted to test the TCN’s by telephone.  Their methodology was highly dubious and unstructured.  In any event, as you can see by the MVM’s own letter to the DoS, MVM never conceded that the TCNs lacked the language proficiency to fulfill the contract requirement.

 

Paragraph 3: This requires some facts to put my response in perspective.  During the period of performance on the Iraq contract, 3DGS fronted some expenses that were supposed to be paid by MVM such as passport fees, airline ticket costs and other travel expenses.  MVM eventually paid these fees but not before several weeks had elapsed.  Accordingly, 3DGS demanded that any expenses that were supposed to be borne by MVM be paid to 3DGS in advance.  The wire transfers records Mr. Rosenblum included in his email are MVM’s advance payments for its own expenses. I have included an accounting of those payments labeled “MVM amount paid report.”  I have also included a report of unpaid invoices showing where the $130,000 demanded by 3DGS came from.

 

I am available this week to discuss future sessions.

 

Best regards,

Haytham Faraj

 

 

               

 

SENT VIA EMAIL @ dlewis@sidley.com

 

David J. Lewis, Esquire

Sidley Austin LLP

1501 K Street, N.W.

Washington, D.C. 20005

 

            Re:       MVM, Inc.; 3D Global Solutions, Inc. vs.

                        Case No: 1:06cv00722 (GK)

                        Our File No. 4647/02

 

Dear Mr. Lewis

 

            Pursuant to your request, enclosed please find scanned copies of the following documents in the above-captioned matter:

 

1.       Letter dated December 9, 2005, from Dario Marquez to Christopher P. Sager with the following attachments:

a.       Supplemental Transition Plan

b.      Testing Statistic

 

2.       ATLA English Proficiency Exam Matrices

 

3.       ATLA Spoken Language Evaluation Candidate Summaries – separated into three parts.

 

4.       Domestic Wire Transfer Detail dated October 17, 2005, from MVM, Inc., to 3D Global Solutions, Inc., in the amount of $51,870.00 for payment of 3D Global Solutions, Inc.’s invoices #2005-104 and #2005-105.  Please note that only the invoice #2005-104 in the amount of $34,650.00 is for the Kabul contract and the other invoice #2005-105 in the amount of $17,220.00 should not be counted.

 

5.       Domestic Wire Transfer Detail dated November 3, 2005, from MVM, Inc., to 3D Global Solutions, Inc., in the amount of $26,351.16 for payment of 3D Global Solutions, Inc.’s invoice #2005-110 and #2005-112.  Please note that both invoices were for the Kabul contract.

 

6.       Kabul Guard Force Training Student Performance Rosters

 

Should you have any questions or concerns, please feel free to contact me.

 

                                                                        Very truly yours,

 

                                                                                    /s/

                                                                                   

                                                                        Herbert S. Rosenblum

 

 

From: Lewis, David J. [mailto:dlewis@Sidley.com]
Sent: Thursday, April 22, 2010 4:51 PM
To: Haytham Faraj; Herbert Rosenblum
Subject: 3D Global Solutions v MVM

 

Counsel

 

I would appreciate it if Mr. Faraj would provide me a couple of the bios that were included in the Administrative Packages and if Mr. Rosenblum would provide me with a copy of MVM’s  December 9, 2005 20-page response to State’s Deficiency Notice, with the attached test results.  The MVM response is referenced in the January 20, 2006 Dickstein Shapiro letter.  Please copy each other when you forward the documents.

 

David J. Lewis
Sidley Austin LLP
1501 K Street, NW
Washington, DC 20005
202-736-8183
202-736-8711 (fax)
dlewis@sidley.com

 

Attachment: Arevalo-Gomez_Part1_21Dec09.pdf
Description: Adobe PDF document

Attachment: Arevalo-Gomez_Part2_21Dec09.pdf
Description: Adobe PDF document

Attachment: Quispe-FLores_Part1_21Dec09.pdf
Description: Adobe PDF document

Attachment: Quispe-FLores_Part2_21Dec09.pdf
Description: Adobe PDF document

Attachment: KO term letter and MVM response Dec 2005.pdf
Description: Adobe PDF document

Attachment: MVm settlemt from Gov march 2006.pdf
Description: Adobe PDF document

Attachment: MVM amount paid report 4_27_10.pdf
Description: Adobe PDF document

Attachment: MVM Calculation unpaid invoices report 4_27_10.pdf
Description: Adobe PDF document