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Saad v. City of Dearborn Heights, et al.



Mr. Clark:

We previously sent you a draft Motion for Reassignment and Notices/Subpoenas regarding the depositions of:  (1) Jeffrey Ross, (2) Rick Duffany, and (3) Lee Gavin.  

You stated that your client would not object to a reassignment of the second action before Judge Duggan; however, we have not heard back from you regarding the substance of our proposed Motion for Reassignment.  Please let me know whether we have your permission to file this Motion so I can avoid filing unilaterally.

Also, please confirm your availability regarding the foregoing depositions.  We have notified the court reporter to be available on those dates.

Since we have not heard back from you regarding our Motion to Amend (to add Defendants) we assume consent is withheld.

Cordially,

Nick

--
____________________________________
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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