Re: City of Dearborn Heights' Supplemental Responses to Plaintiffs' Request for Production of Documents.

We are in receipt of the Booking Videos, Radio Transmissions, and In-car videos enclosed in Defendants' October 6, 2011 correspondence. We note that when we initially requested these, the Defendant City of Dearborn Heights responded that "Defendant has no such recordings." We appreciate your disclosure of the foregoing and acknowledge Defendants' right to supplement its discovery responses (though it is unclear why Defendants would state that these did not exist). That said; we made an identical request for production in Case No. 10-12635 but were never provided with any of the audio or video records and/or audio/video recordings taken by the officers' equipment and/or police cruisers the day of the initial incident (March 10, 2010). Is it Defendants' contention that such audio/video recordings were never taken that day? If these videos are or were in existence when we originally requested them they would contain significant material evidence which we should have been provided with. Accordingly, we hereby request production of the same.

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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

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Direct: 313.415.5559
Office: 313.450.4670
Fax: 313.846.6358
Email:   nhadous@hadousco.com
              www.hadousco.com

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