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Re: Stipulated Order



Patrick,
 
Paragraph 13 is intended to permit Plaintiffs to depose Defendants after the discovery cut-off - it is not intended as an order compelling depositions (since Defendants have not refused to appear for depositions).  Since your email appears to resolve this we will remove paragraph 13 and file the Order.
 
We are working with our client to provide you with further supplements re: Defendants' Interrogatories and should have them to you this week.
 
Cordially,
 
Nick

On Mon, Dec 12, 2011 at 10:55 AM, Patrick Sturdy <psturdy@cmda-law.com> wrote:
Nick,

The proposed order looks acceptable, with the exception of Paragraph 13. Please remove this paragraph from the proposed order. At no time have Defendants ever refused to appear for deposition. In fact, we showed up and you cancelled them during the deposition. As such, it is completely inappropriate to have a discovery order compelling depositions when defendants have never refused to appear for depositions. Additionally, we would be agreeable to the extension of scheduling order dates in order to complete all discovery. Also, Defendants have no intention of refusing to appear for previously requested depositions after the discovery cut-off.

I look forward to hearing from you.

Patrick Sturdy





On 12/9/2011 1:00 PM, Nick Hadous wrote:
Gentlemen,
 
Attached for your review is a Stipulated Order re: Plaintiffs' medical examinations and other discovery.
 
I included a provision re: Defendants' remaining depositions as it appears these will be taken after the discovery cut-off date.
 
Please let me know if this is acceptable and I will file accordingly.
 
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
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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.