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Request for Production No. 2
Gentlemen,
We are writing pursuant to Local Rule 37.1 to "narrow the scope of disagreement" regarding one of our requests for production.
As you know, we previously requested copies of liability insurance policies which cover the Dearborn Heights Police Department and/or the individual officers (Request for Production No. 2).
To date, we have only received your partial response. Please be advised that Fed. R. Civ. P. 26(a)(1)(a)(iv) requires a party to make available for inspection and copying "any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment." Accordingly, we will require these insurance agreements, more specifically, the MMRMA policy, including the the master agreement; umbrella and/or excess insurance policies; reservation of rights; and any and all indemnification policies/documents.
We hope to avoid further burdening the Court with discovery motions. However, if you do not intend to produce the foregoing, please let us know as soon as possible so that we can file a Motion to Compel.
Cordially,
Nick
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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 District Court,
District of Arizona
Eastern District of Michigan
____________________________________
Direct: 313.415.5559
Office: 313.450.4670
Fax: 313.846.6358
Email: nhadous@hadousco.com
www.hadousco.com
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