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| Nov 13, 2007 - Final Notice to Ms. Ouali / ACAM - BRA |
| Copyright © 2009-2013, Marc CAMPUS |
AR 1A 003 871 6703 7
November 13, 2007
Final Notice
Attn: Ms. Imane OUALI
ACAM
Secretariat general - BRA
61 Rue Taitbout
75009-Paris
RE: Ms. Florence Lustman and Ms. Imane Ouali in charge of
TEXAS RIDING LINE Co.’s Claim, # IO/BRA/0420/2006,
and who issued the November 8th, 2006 conclusion.
Please allow this letter to serve two purposes; to respond to your November 8, 2006 letter and to serve
as our final notice of request that this matter be disposed of efficiently.
Since your November 8, 2006 letter, our company has made several, if not numerous, attempts to settle
this matter expeditiously to no avail. Furthermore, our office has had numerous contacts with your entity
dating as far back as February 27, 2006 requesting that this matter be investigated promptly and
professionally. However, you and your entity have failed to perform either of our requests. Our requests
for professionalism were responded to by negligence. Moreover, you failed to conduct and
adequate/thorough investigation; As stated in previous notices: with respect to a proper investigation,
using a totality of the circumstances, the amount of time that a reasonable regulatory agency would have
used under similar circumstances. Your November 8th letter stated that you found no wrong doing on the
part of Mr. Duchan and MMA. Furthermore, you stated that, under French law, in order to succeed the
victim must prove the existence of damages prior to obtaining relief. However, plaintiff’s injury can be
directly traced to MMA/Mr. Duchan. As such, your argument lacks merit and is arbitrary. Moreover, since
your November 8, 2006 letter, our company has lost valuable time, in the form of 11 months waiting for
an adequate investigation.
We have requested your cooperation with investigating bad faith allegations. Had Ms. Lustman and Ms.
Ouali conducted a proper and thorough investigation, in the form of reports, exhibits, letters, etc...,
against MMA/Mr. Duchan, plaintiff would not be delayed in obtaining justice. Neither would plaintiff have
been subjected to an arbitrary decision not based in law or fact. Because of your actions, our company
has suffered irreparable harm/injury in the form of unnecessary delays. The delay in receiving payment
from MMA for its bad faith and unfair business settlement practices has caused plaintiffs irreparable
pecuniary loss; an amount to be proven in the event of litigation. As such, contrary to your earlier
assertion, plaintiff has met all necessary elements to prove both negligence and damages.
Furthermore, because of Ms. Lustman’s, Ms. Ouali’s, ACAM’s blatant disregard for our company’s well
being, CS 1 GROUP LEGAL OFFICE Co. continues to experience business obstacles. Because of your
actions, or the lack thereof, we are requesting that you and your office pay an advance partial payment.
This will show good faith on your part thereby beginning the repair process without more unnecessary
delay. This will also allow CS 1 GROUP LEGAL OFFICE Co. to efficiently protect its current/new business
interests. Our company has experienced damages in the form of damages to business reputation (also
known as good will) and lost time; time that could have been utilized to further our business ventures
without the unnecessary distraction caused by yours and your organization’s failure to timely resolve this
matter. If this matter is not resolved within 10 business days of receipt of this certified notice, we will
promptly pursue this matter via litigation by filing a lawsuit against you, Ms. Lustman, Ms. Ouali and the
entity ACAM you have represented, before the United States Federal Court.
I hope that this matter can be resolved without any more unnecessary delay.
Sincerely,
CS 1 GROUP LEGAL OFFICE Co.
Marie Campus, Director
November 13, 2007
Final Notice
Attn: Ms. Imane OUALI
ACAM
Secretariat general - BRA
61 Rue Taitbout
75009-Paris
RE: Ms. Florence Lustman and Ms. Imane Ouali in charge of
TEXAS RIDING LINE Co.’s Claim, # IO/BRA/0420/2006,
and who issued the November 8th, 2006 conclusion.
Please allow this letter to serve two purposes; to respond to your November 8, 2006 letter and to serve
as our final notice of request that this matter be disposed of efficiently.
Since your November 8, 2006 letter, our company has made several, if not numerous, attempts to settle
this matter expeditiously to no avail. Furthermore, our office has had numerous contacts with your entity
dating as far back as February 27, 2006 requesting that this matter be investigated promptly and
professionally. However, you and your entity have failed to perform either of our requests. Our requests
for professionalism were responded to by negligence. Moreover, you failed to conduct and
adequate/thorough investigation; As stated in previous notices: with respect to a proper investigation,
using a totality of the circumstances, the amount of time that a reasonable regulatory agency would have
used under similar circumstances. Your November 8th letter stated that you found no wrong doing on the
part of Mr. Duchan and MMA. Furthermore, you stated that, under French law, in order to succeed the
victim must prove the existence of damages prior to obtaining relief. However, plaintiff’s injury can be
directly traced to MMA/Mr. Duchan. As such, your argument lacks merit and is arbitrary. Moreover, since
your November 8, 2006 letter, our company has lost valuable time, in the form of 11 months waiting for
an adequate investigation.
We have requested your cooperation with investigating bad faith allegations. Had Ms. Lustman and Ms.
Ouali conducted a proper and thorough investigation, in the form of reports, exhibits, letters, etc...,
against MMA/Mr. Duchan, plaintiff would not be delayed in obtaining justice. Neither would plaintiff have
been subjected to an arbitrary decision not based in law or fact. Because of your actions, our company
has suffered irreparable harm/injury in the form of unnecessary delays. The delay in receiving payment
from MMA for its bad faith and unfair business settlement practices has caused plaintiffs irreparable
pecuniary loss; an amount to be proven in the event of litigation. As such, contrary to your earlier
assertion, plaintiff has met all necessary elements to prove both negligence and damages.
Furthermore, because of Ms. Lustman’s, Ms. Ouali’s, ACAM’s blatant disregard for our company’s well
being, CS 1 GROUP LEGAL OFFICE Co. continues to experience business obstacles. Because of your
actions, or the lack thereof, we are requesting that you and your office pay an advance partial payment.
This will show good faith on your part thereby beginning the repair process without more unnecessary
delay. This will also allow CS 1 GROUP LEGAL OFFICE Co. to efficiently protect its current/new business
interests. Our company has experienced damages in the form of damages to business reputation (also
known as good will) and lost time; time that could have been utilized to further our business ventures
without the unnecessary distraction caused by yours and your organization’s failure to timely resolve this
matter. If this matter is not resolved within 10 business days of receipt of this certified notice, we will
promptly pursue this matter via litigation by filing a lawsuit against you, Ms. Lustman, Ms. Ouali and the
entity ACAM you have represented, before the United States Federal Court.
I hope that this matter can be resolved without any more unnecessary delay.
Sincerely,
CS 1 GROUP LEGAL OFFICE Co.
Marie Campus, Director
