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Re: Saad, Joseph & Zihra v Dearborn Heights



Mr. Sturdy,
 
We have made repeated inquiries (email, telephone and letter) regarding the audio/video recordings from both incidents giving rise to the Plaintiffs' actions.  Neither you nor Mr. Clark have been responsive to any of our inquiries until your letter dated October 28, 2011 (save for your earlier comment that audio/video recordings in the earlier action were not "relevant" and a "waste of time).
 
We do not impart improper conduct by you, Mr. Clark, or any of the CMDA, PLC attorneys; however, as indicated in previous emails, we have stated that your silence and complete disregard for our inquires are not "helpful."  In any event, your contention that my my assertion regarding whether the audio/video recordings contain exculpatory evidence is "false" will surely be tested.
 
I am confident my email correspondences (among other things) will allow the Court to see precisely what was requested/stated and when.
 
Further, while we appreciate your disclosure of the dispatch recordings from the earlier incident, we note that when we requested these back in August 2010, your client responded, "Defendant has no such tapes."
 
 
Cordially,
 
Nick
 
 
 
 
On Fri, Oct 28, 2011 at 4:10 PM, Diane M. Waldenmayer <dwaldenmayer@cmda-law.com> wrote:
Dear Mr. Hadous:

Please see the attached correspondence from Patrick R. Sturdy.

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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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____________________________________
HADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ

Nick N. Hadous
Admitted:
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-  State Bar of California
-  United States District Court,
    District of Arizona
     Eastern District of Michigan
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