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] 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 |
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