Re: Saad, Joseph & Zihra v Dearborn Heights

We previously agreed to make Plaintiffs available for the Defendants' medical examinations even though we were not provided with a copy of Dr. Ager's current curriculum vitae within the time prescribed by the Stipulated Order entered December 15, 2011 (the "Order"). As a courtesy, as well as to expedite this litigation, we agreed to make our clients available for these examinations provided that a current copy of Dr. Ager's curriculum vitae was provided to us by no later than noon tomorrow.

We assume Dr. Ager was provided with a copy of the Order (which was one of the stipulations) and is therefore aware that he is to provide Plaintiffs with a current version including a list of all previous trials and trial depositions for which he appeared. Since the Order was dated December 9, 2011 (entered December 15, 2011), there appears to have been ample time for Dr. Ager to provide a current curriculum vitae.

Please note that the curriculum vitae of Dr. Ager you provided to us appears current as of May/November 2010. As we are nearing February 2012, this would not appear to be a current curriculum vitae. Accordingly, please provide us with Dr. Ager's current curriculum vitae as required by the Order.

In the event a current version does not exist (i.e., the version you provided to us is the most current), we would be willing to accept a supplemental list of trials and trial depositions for which Dr. Ager has appeared as of May 24, 2010 (the last one listed on the curriculum vitae you provided to us); provided, however, we receive this list by no later than noon tomorrow (since the examinations are Friday), and an updated curriculum vitae is provided to us within a reasonable time.

On Wed, Jan 25, 2012 at 4:28 PM, Diane M. Waldenmayer <dwaldenmayer@cmda-law.com> wrote:

Dear Mr. Hadous:

Please see the attached correspondence from Mr. Sturdy along with Dr. Ager's Curriculum Vitae.

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Diane M. Waldenmayer
Cummings, McClorey, Davis, & Acho, P.L.C.
33900 Schoolcraft Road
Livonia, Michigan 48150
E-mail: dwaldenmayer@cmda-law.com
Phone: (734)261-2400 Ext. 1298
Fax: (734)261-4510

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