That’s correct. I spoke to them today and asked them to pay and prepare their responses. They will send them to me first for review. Once I review, I will forward to you to draft in the correct format for the response. I would also like you to begin to thing about our production and interrogatories to Jandali. I am very interested in finding out who is behind this law suit. Clearly there are some political motivations here. From: MaryJo Provenzano [mailto:maryjo1@puckettfaraj.com] Haytham: OK, I have already reviewed and know which ones I am objecting to and which ones we will need to press the client to comply with. I think we know some of the answers but they have been less than forthcoming with documentation. Do I understand correctly that I am not allowed to proceed with drafting responses to these discovery requests until you have discussed/received funds from the client? Mary Jo From: Haytham Faraj [mailto:haytham@puckettfaraj.com] For your review. From: McNutt, Steve [mailto:Steven.McNutt@troutmansanders.com] Dear Haytham and Michael: Attached are Plaintiff Malek Jandali’s First Set of Document Requests and Interrogatories. Hard copies are being sent to you via First Class Mail. Regards, Steve Steven W. McNutt IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice that may be contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction(s) or tax-related matter(s) that may be addressed herein. This e-mail communication (including any attachments) may contain legally privileged and confidential information intended solely for the use of the intended recipient. If you are not the intended recipient, you should immediately stop reading this message and delete it from your system. Any unauthorized reading, distribution, copying or other use of this communication (or its attachments) is strictly prohibited. No virus found in this message. |