Mr. Hadous,
I do not agree that the policies and procedures are not confidential information. However, notwithstanding this, we agree to modify the protective order portion of order as requested by adopting the language contained within the protective order issues in Case No. 07-10731. Additionally, I have amended to title of the motion to indicate that your Motion to Compel was granted in part and denied in part. I plan on submitting this to the Court shortly after 4:00 so please let me know of any legitimate concerns prior to that time. Finally, it is my understanding that you wish to discuss your clients attendance at the IME. I look forward to hearing from you on this matter.
Patrick Sturdy
On 11/22/2011 11:53 AM, Nick Hadous wrote:I would request the following changes:1. Modify the language to reflect that Plaintiffs' Motion was granted in part and denied in part.2. The terms of the proposed protective order are unacceptable as: (1) the Manual is not confidential information; and (2) the terms unreasonably limit or ability to use and introduce evidence.We would suggest a shorter protective order essentially identical to the order issued in Case No. 07-10731.Cordially,Nick
On Tue, Nov 22, 2011 at 11:28 AM, Patrick Sturdy <psturdy@cmda-law.com> wrote:
Mr. Hadous,
Can you please explained what is unacceptable? I believe the order as proposed accurately reflects the Court's Ruling. I look forward to hearing from you so that we can clear up any misunderstanding that may exist.
Thank you,
Patrick Sturdy
On 11/22/2011 11:10 AM, Nick Hadous wrote:Mr. Sturdy,This proposed Order is unacceptable. Can you please send me a Word version so that I can revise accordingly?Cordially,Nick
On Tue, Nov 22, 2011 at 10:53 AM, Diane M. Waldenmayer <dwaldenmayer@cmda-law.com> wrote:
Dear Mr. Hadous:
Please see the attached correspondence and proposed Order from Mr. Sturdy. I will also put a hard copy in the mail to you.
--
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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Nick N. HadousAdmitted:- State Bar of Arizona- State Bar of California- United States District Court,District of ArizonaEastern District of Michigan
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CONFIDENTIALITY NOTICEThis e-mail correspondence is confidential. If you are not the intended recipient, please notify the sender of the delivery error immediately, and then delete it from your system. Do not read, use, or copy this e-mail, or disclose it to others. This e-mail is not intended to waive the attorney-client privilege, or any other privilege. Thank you.
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____________________________________
HADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ
Nick N. HadousAdmitted:- State Bar of Arizona- State Bar of California- United States District Court,District of ArizonaEastern District of Michigan
____________________________________
Direct: 313.415.5559
Office: 313.450.4670
Fax: 313.846.6358
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.
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CONFIDENTIALITY NOTICEThis e-mail correspondence is confidential. If you are not the intended recipient, please notify the sender of the delivery error immediately, and then delete it from your system. Do not read, use, or copy this e-mail, or disclose it to others. This e-mail is not intended to waive the attorney-client privilege, or any other privilege. Thank you.