Plaintiffs' Request for Production of Documents

[Nick Hadous <nhadous@hadousco.com>]

Gentlemen:

 

We are awaiting your response regarding whether any of the in-car audio/video recordings were produced by the City of Dearborn Heights to CMDA in the first action (discovery we requested).  

 

If we do not hear a response from you, we will assume that you advised your client to withhold this evidence.  As you know, similar evidence was withheld from my clients' defense attorneys during the criminal proceedings against them.  If we are mistaken in our presumption, please let us know -- your silence is not helpful.

 

Further, I am unsure why you are forwarding invoices regarding from a medical provider you hired when you did not obtain a court order to conduct the IMEs, or, at the very least, consult with me or Haytham regarding our clients' availability prior to scheduling.

 

Your anticipated cooperation is greatly appreciated.

 

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
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Email:    nhadous@hadousco.com
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