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Fwd: Defendants' Personnel Files



Mr. Sturdy,
 
We previously requested that you let us know whether you redacted any pages from any of the individually-named Defendants' personnel files in their entireity.  To date, we have not received your response.  Accordingly, we hereby request that you provide us with a "privilege log"pursuant to Fed. R. Civ. P. 26(b)(5) regarding your assertion of a privilege regarding the redacted material.
 
We will forward a cover letter (hard copy) via postal mail to your attention.
 
Cordially,
 
Nick

---------- Forwarded message ----------
From: Nick Hadous <nhadous@hadousco.com>
Date: Tue, Jan 24, 2012 at 11:27 AM
Subject: Defendants' Personnel Files
To: Patrick Sturdy <psturdy@cmda-law.com>, "Jeffrey R. Clark" <jclark@cmda-law.com>
Cc: Haytham Faraj <haytham@puckettfaraj.com>


Mr. Sturdy,
 
You previously provided us with the individually-named Defendants' personnel files.  You identified these as "redacted" personnel files.  Were any pages redacted in their entirety (i.e., pulled from the file and not included in the disclosure?)  
 
Cordially,
 
Nick

--
____________________________________
HADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ


Nick N. Hadous
Admitted:
-  State Bar of Arizona
-  State Bar of California
-  United States Courts,
     Sixth Circuit Court of Appeals
     District of Arizona
     Eastern District of Michigan
____________________________________

Direct:    313.415.5559
Office:    313.450.4670
Fax:        888.450.0687
Email:    nhadous@hadousco.com
              
www.hadousco.com

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that, to the extent that this communication or any attachment addresses a tax matter, it was not written to be (and may not be) relied upon to (i) avoid tax-related penalties under the Internal Revenue Code; or (ii) promote, market or recommend to another party any transaction or matter addressed herein or in any such attachment.

CONFIDENTIALITY NOTICE: This email message and all attachments transmitted with it are intended solely for the use of the addressees and may contain legally privileged, protected or confidential information. If you have received this message in error, please notify the sender immediately by email reply and please delete this message from your computer and destroy any copies.




--
____________________________________
HADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ


Nick N. Hadous
Admitted:
-  State Bar of Arizona
-  State Bar of California
-  United States Courts,
     Sixth Circuit Court of Appeals
     District of Arizona
     Eastern District of Michigan
____________________________________

Direct:    313.415.5559
Office:    313.450.4670
Fax:        888.450.0687
Email:    nhadous@hadousco.com
              
www.hadousco.com

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that, to the extent that this communication or any attachment addresses a tax matter, it was not written to be (and may not be) relied upon to (i) avoid tax-related penalties under the Internal Revenue Code; or (ii) promote, market or recommend to another party any transaction or matter addressed herein or in any such attachment.

CONFIDENTIALITY NOTICE: This email message and all attachments transmitted with it are intended solely for the use of the addressees and may contain legally privileged, protected or confidential information. If you have received this message in error, please notify the sender immediately by email reply and please delete this message from your computer and destroy any copies.