Saad v. City of Dearborn Heights, et al (2:11 - cv - 1013)

[Nick Hadous <nhadous@hadousco.com>]

Mr. Clark,

 

We are writing pursuant to Local Rule 37.1 to "narrow our areas of disagreement" regarding a discovery matter. 

 

We disagree with Defendants' objections and assertion of a "privilege" regarding Plaintiffs' First Requests for Production of Documents to the Defendant City of Dearborn Heights Nos. 9-20 (regarding the personnel records of the Dearborn Heights Police Officers who were involved in the Saad incident) (the "Requests").

 

It is the Plaintiffs' position that our Requests are pertinent to this action and that the information sought is within the purview of Fed. R. Civ. P. 26(b)(1). 

 

On what basis does Defendant assert a "privilege"? 

 

We genuinely hope to avoid filing a discovery-related motion and using the Court's limited resources for something we can resolve amongst ourselves.  However, if we must file a Motion to Compel Discovery, we will seek all appropriate costs and remedies.

 

We note that you are aware that we plan on deposing the individually-named police officers within the next few weeks.   We further note that you are aware that the discovery cut-off is approaching.   Accordingly, we would ask that you please provide us with a prompt response to enable us to proceed without suffering undue prejudice.

 

We remind you that an identical request to Defendant Krause in the related action was not deemed objectionable.  We can only surmise that Defendants are now objecting because Plaintiffs intend to call as witnesses in the related action certain individuals who have reported virtually identical (abusive and unlawful) conduct by Defendant Krause. 

 

Time is of the essence.

 

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

____________________________________

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Email:    nhadous@hadousco.com
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