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Re: IME re: Joseph Saad



Mr. Clark,
 
The Saads will provide convenient dates by the end of the week.  Also, we have not heard back from you regarding the presence of our own examiner and a recording method.  If we do not hear back from you we will assume you have no objection to the presence of our examiner and recording by audio means.
 
Also, we have not heard back from you regarding the discovery correspondence we sent last Friday.  We hope you will help us resolve these matters amongst the parties. 
 
Cordially,
 
Nick

On Fri, Oct 14, 2011 at 10:52 AM, Nick Hadous <nhadous@hadousco.com> wrote:
I will follow-up with her today and let you know by Monday. We would like our own independent medical examiner to be present during the IME.  Further, we feel that the parties are best served if the IME is recorded by audio means. 
 
Cordially,
 
Nick

On Thu, Oct 13, 2011 at 2:29 PM, Jeffrey R. Clark <jclark@cmda-law.com> wrote:
Thank you.  Will Mrs. Saad be able to keep her scheduled date?


nhadous@hadousco.com wrote:
I don't think a court order will be necessary.
Sent on the Sprint® Now Network from my BlackBerry®

-----Original Message-----
From: "Jeffrey R. Clark" <jclark@cmda-law.com>
Date: Thu, 13 Oct 2011 12:26:50 To: Nick Hadous<nhadous@hadousco.com>
Subject: Re: IME re: Joseph Saad

Now that discover has been extended we are not under timing pressures. We will coordinate dates as so as possible.  Are you insisting on a court order for your clients' IMEs?  Jeff

Nick Hadous wrote:
Mr. Clark,
 Mr. Saad has informed me that he will be unable to attend the IME tomorrow.  I will check with him regarding his availability and revert to you.  In the future, if you are going to schedule an IME absent a court order, please check with me or Haytham regarding our clients' availability.
 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

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.





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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

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.