Saad v. City of Dearborn Heights, et al (Response to Correspondence Dated September 14, 2011 and Plaintiffs' Request for Corrected Discovery Responses)

Please note that we still require the complete personnel files of the individually named Defendants. We attempted to contact Mr. Clark by telephone and by email multiple times regarding this issue. To date, we have received absolutely no response. With depositions and discovery cut-off looming we will suffer prejudice. Mr. Clark would appear to be aware that there is nothing privileged about these records as evidenced by his previous disclosure of Defendant Krause's personnel file in the related action (Case No. 10-12635).

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