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NOTICE OF SUBPOENA - Saad v. City of Dearborn Heights, et al.
Gentlemen:
We are writing pursuant to Fed. R. Civ. P. 45(b)(1). Please take notice that Plaintiffs plan to issue subpoenas regarding all documents/records received by Mark Haidar and the Assistant Wayne County Prosecutors Kal Najjar and Jamil Khuja in People v. Joseph Saad (Case No. 10-8999) by no later than Monday.
Also, we should be receiving the Plaintiffs' medical records on Friday. We anticipate producing these sometime next week provided we have had ample opportunity to redact irrelevant and/or privileged portions thereof.
Plaintiffs do not agree to an IME on the terms/conditions you suggested. We are willing to discuss reasonable terms/conditions regarding the IME not unlike those previously agreed upon in earlier cases.
As always, we are available to discuss any discovery-related issue/concerns.
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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