This email will confirm that on Wednesday, November 9, 2011, you have requested the deposition of the witnesses listed below. Today is November 10, 2011. We are in the process of obtaining dates from our clients and will provide those dates shortly. As you are aware, the depositions have been scheduled numerous times in the past only to be cancelled by you at the last second, even though Defendants have appeared and been prepare to go forward with the depositions. Defendants will continue to cooperate with discovery as they have in the past.
Sincerely,
Patrick R. Sturdy
Attorney for Defendants
On 11/9/2011 12:53 PM, Nick Hadous wrote:
Gentlemen,Please provide us with convenient dates for depositions of the following parties:1. Defendant Keller2. Lee GavinIf we do not hear from you by the end of the week we will schedule these depositions unilaterally.Cordially,Nick
--
____________________________________
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.
CONFIDENTIALITY NOTICE
This 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.