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| Copyright © 2009-2013, MARC CAMPUS |
August 31, 2007
RE: Mamoud Abbas, PA Chairman
Mme Khoury’s Palestinian Representative in Paris
Dear Mr. Abbas:
This letter serves two purposes; to inform you of our position regarding your alleged breaches of contract, fiduciary duty,
unjust enrichment, and fraudulent business practices and to serve as our final notice requesting that this matter be settled
within fifteen (15) days of this letter.
Our organization has made numerous contacts in order to build a world-famous equestrian business; an effort rewarded
by a June 24, 1995 meeting in Gaza between Mrs. Maquard and PA Chairman Yasser Arafat (Arafat) and the further
signatures of 2 agreements, which stated the following:
1st : with Palestinian Union of Equitation (hereinafter “PUE”) – Gaza (June 26, 1995) Marc Campus representing himself
and Suheil Abed representing PUE
and
2nd : with AL-BAHAR Ltd Co. (March 2, 1996). However, with any great accomplishment comes struggle. First of all, a “gift”
was made to your organization. However, this gift was conditioned upon Mrs. Maquard and Mr. and Mrs. Campus being in
charge of the horses' care and training. Furthermore, this transfer was additionally conditioned on the undertaking by the
PUE to provide support, buildings, training facilities, and accommodations for the horses and for Ms. Maquard and Mr. and
Mrs. Campus. None of these conditions were met and the objectives of the transfer of the horses to the Palestinians have
not been achieved because of those failures. Moreover, the Arabian horse “Manar”, with an estimated value of over
$1,000,000.00 was not part of the original offer or contract. However, it has been retained. Last but not least, it is our
contention that unauthorized breeding, in essence, breeding without just compensation has occurred.
We assert that your organization committed both fraud and breach of fiduciary duty. In order to prove fraud, a plaintiff must
establish: (1) a false representation of a material existing fact; (2) knowledge on the part of the one making the
representation that it is false; (3) ignorance on the part of the one to whom the representation is made of the falsity; (4) that
the representation was made with the intention that it be acted upon; and (5) damage caused by the representation. As
such, we assert that, based on your actions, you never had any intention of performing the terms of the contract at issue.
On the other hand, a claim for breach of fiduciary duty will be sustained once we prove that we have incurred damages and
that the defendant's breach of fiduciary duty was a cause of the damages sustained. A portion of damages and requests
are listed below. Any additional amount will be proven in the event of future litigation in front of a United States jury
which will carry on generous punitive damages verdict. As a result of the above causes of action concerning “Manar” US
Purebred Arab Stallion and other actions, you have been unjustly enriched. A cause of action for unjust enrichment arises
when the plaintiff proves the following: 1) a benefit was conferred upon a defendant, 2) the defendant did not pay the
reasonable value for said benefit, and 3) it would be unjust for the defendant to retain said benefit without paying the
reasonable value for that benefit. As applied here, in addition to unauthorized breeding, your organization has violated the
terms of the agreement at issue, a cause of action for breach of contract.
Said breach occurs when: 1) a valid contract exists between two parties and 2) one party fails to perform (breaches) the
contract without good cause. Here, you have failed to provide our organization with any reason for not performing the terms
of the contract.
The terms of the contract giving rise to this letter and potential litigation required Ms. Maquard and Mr. and Mrs. Campus to
take responsibility for the manufacture, design, and market the products for 10% of the selling price, provide technical
advice and report monthly expenses, refrain from working in competitive situation, and take a 10% commission. The
above-mentioned parties performed the terms of the contract. Furthermore, pursuant to the contract, Al Bahar agreed to
finance the fabrication of the clothing and boot manufacture, and other items related to horses and riders, provides Ms.
Maquard and Mrs. Campus a monthly salary of $1,000, and to give Mr. Campus $20,000 toward expenses of marketing
and advertising with the expenses to be deducted from commissions. Furthermore, Al Bahar was to support the
establishment of a marketing effort in Quebec, Canada. Unfortunately, these contractual terms were never fully performed.
Due to your willful and unjustified unfair business practices in the form of fraud, breach of contract, and breach of fiduciary
duty, we hereby requests that this matter be settled within 15 days of this letter to avoid impending United States Federal
Court litigation. Further, plaintiff requests the following:
1- Repayment of Mrs. Campus’ past salary, unpaid since Sept 1996 until now, for a total of US $134,000.00 + interest
2- Repayment of Mr. Campus’ Stallions as of Importation Value declaration US$1,550,000.00
3- Indemnity for breeding service
The agreement made with Arafat (in June of 1995), confirmed by signatures on both contracts (June 26, 1995 and Mar
2, 1996), is still valid and has never been denounced by Palestine Official Representatives. Last but not least, we have
been trying to resolve this matter for some time now to no avail. Additional fraud was committed when the
Palestinian government representatives were made aware about the Government businesses failures and they chose
to ignore the rightful requests. The Palestinian government failed to act in good faith which has caused to suffer
additional and perpetuating damages.
Our organization is one of excellence-both in our transactions with clients and co-workers and has built a strong business
reputation; a fact to which numerous individuals would attest.
Please have your response sent to Marc Campus and CS 1 Group Legal Office Co. USA.
I hope that this matter can be handled without any more unnecessary delay.
Sincerely,
CS 1 GROUP LEGAL OFFICE Co.
Marie Campus,
Director
RE: Mamoud Abbas, PA Chairman
Mme Khoury’s Palestinian Representative in Paris
Dear Mr. Abbas:
This letter serves two purposes; to inform you of our position regarding your alleged breaches of contract, fiduciary duty,
unjust enrichment, and fraudulent business practices and to serve as our final notice requesting that this matter be settled
within fifteen (15) days of this letter.
Our organization has made numerous contacts in order to build a world-famous equestrian business; an effort rewarded
by a June 24, 1995 meeting in Gaza between Mrs. Maquard and PA Chairman Yasser Arafat (Arafat) and the further
signatures of 2 agreements, which stated the following:
1st : with Palestinian Union of Equitation (hereinafter “PUE”) – Gaza (June 26, 1995) Marc Campus representing himself
and Suheil Abed representing PUE
and
2nd : with AL-BAHAR Ltd Co. (March 2, 1996). However, with any great accomplishment comes struggle. First of all, a “gift”
was made to your organization. However, this gift was conditioned upon Mrs. Maquard and Mr. and Mrs. Campus being in
charge of the horses' care and training. Furthermore, this transfer was additionally conditioned on the undertaking by the
PUE to provide support, buildings, training facilities, and accommodations for the horses and for Ms. Maquard and Mr. and
Mrs. Campus. None of these conditions were met and the objectives of the transfer of the horses to the Palestinians have
not been achieved because of those failures. Moreover, the Arabian horse “Manar”, with an estimated value of over
$1,000,000.00 was not part of the original offer or contract. However, it has been retained. Last but not least, it is our
contention that unauthorized breeding, in essence, breeding without just compensation has occurred.
We assert that your organization committed both fraud and breach of fiduciary duty. In order to prove fraud, a plaintiff must
establish: (1) a false representation of a material existing fact; (2) knowledge on the part of the one making the
representation that it is false; (3) ignorance on the part of the one to whom the representation is made of the falsity; (4) that
the representation was made with the intention that it be acted upon; and (5) damage caused by the representation. As
such, we assert that, based on your actions, you never had any intention of performing the terms of the contract at issue.
On the other hand, a claim for breach of fiduciary duty will be sustained once we prove that we have incurred damages and
that the defendant's breach of fiduciary duty was a cause of the damages sustained. A portion of damages and requests
are listed below. Any additional amount will be proven in the event of future litigation in front of a United States jury
which will carry on generous punitive damages verdict. As a result of the above causes of action concerning “Manar” US
Purebred Arab Stallion and other actions, you have been unjustly enriched. A cause of action for unjust enrichment arises
when the plaintiff proves the following: 1) a benefit was conferred upon a defendant, 2) the defendant did not pay the
reasonable value for said benefit, and 3) it would be unjust for the defendant to retain said benefit without paying the
reasonable value for that benefit. As applied here, in addition to unauthorized breeding, your organization has violated the
terms of the agreement at issue, a cause of action for breach of contract.
Said breach occurs when: 1) a valid contract exists between two parties and 2) one party fails to perform (breaches) the
contract without good cause. Here, you have failed to provide our organization with any reason for not performing the terms
of the contract.
The terms of the contract giving rise to this letter and potential litigation required Ms. Maquard and Mr. and Mrs. Campus to
take responsibility for the manufacture, design, and market the products for 10% of the selling price, provide technical
advice and report monthly expenses, refrain from working in competitive situation, and take a 10% commission. The
above-mentioned parties performed the terms of the contract. Furthermore, pursuant to the contract, Al Bahar agreed to
finance the fabrication of the clothing and boot manufacture, and other items related to horses and riders, provides Ms.
Maquard and Mrs. Campus a monthly salary of $1,000, and to give Mr. Campus $20,000 toward expenses of marketing
and advertising with the expenses to be deducted from commissions. Furthermore, Al Bahar was to support the
establishment of a marketing effort in Quebec, Canada. Unfortunately, these contractual terms were never fully performed.
Due to your willful and unjustified unfair business practices in the form of fraud, breach of contract, and breach of fiduciary
duty, we hereby requests that this matter be settled within 15 days of this letter to avoid impending United States Federal
Court litigation. Further, plaintiff requests the following:
1- Repayment of Mrs. Campus’ past salary, unpaid since Sept 1996 until now, for a total of US $134,000.00 + interest
2- Repayment of Mr. Campus’ Stallions as of Importation Value declaration US$1,550,000.00
3- Indemnity for breeding service
The agreement made with Arafat (in June of 1995), confirmed by signatures on both contracts (June 26, 1995 and Mar
2, 1996), is still valid and has never been denounced by Palestine Official Representatives. Last but not least, we have
been trying to resolve this matter for some time now to no avail. Additional fraud was committed when the
Palestinian government representatives were made aware about the Government businesses failures and they chose
to ignore the rightful requests. The Palestinian government failed to act in good faith which has caused to suffer
additional and perpetuating damages.
Our organization is one of excellence-both in our transactions with clients and co-workers and has built a strong business
reputation; a fact to which numerous individuals would attest.
Please have your response sent to Marc Campus and CS 1 Group Legal Office Co. USA.
I hope that this matter can be handled without any more unnecessary delay.
Sincerely,
CS 1 GROUP LEGAL OFFICE Co.
Marie Campus,
Director
