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Re: Depositions



Patrick,
 
I will review and return to you.  Regarding the depositions, we are flexible to rescheduling to mutually convenient dates/times.  However, as discussed, Plaintiffs will insist on conducting the depositions in the order noticed.  Please let me know if this will be an issue. 
 
Cordially,
 
Nick

On Thu, Dec 15, 2011 at 3:02 PM, Patrick Sturdy <psturdy@cmda-law.com> wrote:
Nick,

Please find attached the proposed order extending scheduling order dates 60 days. Please let me know if you have any concerns. If there are none, please execute and return to my office for filing with the USDC.

I also want to confirm our conversation yesterday regarding your unilateral selection of depositions dates. During our conversation, you agreed that the unilateral selection of dates was simply to preserve your request to take the deposition of the individual contained on the notice, and that depositions would proceed on mutually convenient dates for all parties. If my understand regarding our conversation is wrong, please let me know.

Thanks for your cooperation regarding this.

Sincerely,

Patrick








On 12/14/2011 12:46 PM, Nick Hadous wrote:
Dear Mr. Sturdy:
 
Please find attached our cover letter and notices of deposition.
 
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

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--
____________________________________
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.