Today, we talk.
-----Original Message-----
From: Serena Patel
To: Yo
Cc: Janet Bashen
Sent: Fri, Jan 18, 2019 4:22 pm
Subject: Yo v. Bashen Corporation
Good afternoon,
My name is Serena Patel, and I am the attorney representing Bashen Corporation in your lawsuit against Bashen Corporation, J5-CV-18-. Janet Bashen, the CEO of Bashen Corporation, and I just called you, but you did not answer and we were unable to leave a voicemail. We would like to discuss the case and a possible settlement with you as soon as possible. Please respond to this email with your availability or call us back at your earliest convenience.
Thank you very much,
Serena Patel, Esq.
Director
2603 Augusta Dr., Suite 200
Houston, Texas 77057
Phone: 713-780-8056
Fax: 713-780-8206
Via
email to: JP5Civil@traviscountytx.gov
The Honorable Nicholas Chu
Justice of the Peace
Precinct Five
1000 Guadalupe Street, Suite 117
Austin, TX 78701
Re: Yo v. Bashen
Corporation, Cause No. J5-CV-18-
Petition
to Deny Defendant’s Request to Transfer Venue
Dear Hon. Nicholas Chu,
As the Plaintiff in
Case No. J5-CV-18-, I respectfully requests the Court deny the Defendant’s
request to transfer the case from Travis County to Harris County in the
interest of justice and convenience of me, the Plaintiff.
I am the Plaintiff, suing Bashen
for refusing to pay fees and reimburse travel expenses incurred during the
months of June, July, and August 2018 while contracted by Bashen as an EEO
Mediator/Facilitator to provide services to the Department of Veterans Affairs
(VA) for a Group Facilitation in Austin, Texas. Fees and expenses that have
been paid by Veterans Affairs to Bashen. To add injury, the Contracting Officer
emailed all parties indicating that Bashen was paid for at least my first
invoice for the month of June 2018. Bashen never compensated me. In addition,
Bashen made defamatory remarks that attacked my character, integrity, and
ethics – and my oath to the United States Constitution, Public Trust and
National Security Clearance.
There does not exist an
Independent Contractor Mediator & Non-Disclosure Agreement (attached as
Exhibit 1 by the Defendant) between Bashen and myself, as indicated by the
absence of my signature. I have never seen this form before.
I have relocated to Atlanta,
Georgia. I have already purchased my ticket to Austin (attached as Exhibit 1).
Austin is the location of Bashen’s Resident Agent at the time of filing as
provided by the State of Texas.
I plea to the Court to denying the
Defendant’s request to transfer venue and to continue the trial date currently
set for January 31, 2019, at 10:30 a.m. as the contrary to both will continue
the economic, personal and emotional hardship already caused by Bashen for deliberate
non-payment of fees and reimbursement travel expenses.
In addition, I am one of the
800,000 Federal Furloughed Employees, in a non-pay status due to the government
shutdown – and cannot absorb the related costs or the delay (attached as
Exhibit 2).
Respectfully,
