RE: FW: Attached image data

She sent the document directly to you. You cc’d me on the response. I never saw the attachment

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

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From: Nick Hadous [mailto:nhadous@hadousco.com]
Sent: Monday, July 26, 2010 12:20 PM
To: Sabon-Ellerbrake, Laurie
Cc: Haytham Faraj
Subject: Re: FW: Attached image data

Ms. Ellerbrake,

We have no problem stipulating to a 30-day extension.

Cordially,

Nick

On Mon, Jul 26, 2010 at 8:45 AM, Sabon-Ellerbrake, Laurie <lellerbrake@ci.dearborn.mi.us> wrote:

Mr. Hadous --

Thank-you for your response.

I would be happy to present Officer Mullins for an interview. However, I am starting a trial in federal court shortly and my schedule is booked with pretrial matters. Is is possible to stipulate to a 30-day extension for me to answer your Complaint? Then, when the trial is over (probably around August 6) I will arrange for the interview.

Your cooperation is appreciated.

Laurie M. Ellerbrake

Deputy Corporation Counsel

City of Dearborn

13615 Michigan Avenue

Dearborn, Michigan 48126

313.943.2035

313.943.2469 (fax)

lellerbrake@ci.dearborn.mi.us

From: Nick Hadous [mailto:nhadous@hadousco.com]
Sent: Friday, July 23, 2010 1:36 PM
To: Sabon-Ellerbrake, Laurie
Cc: Haytham Faraj
Subject: Re: FW: Attached image data

Ms. Ellerbrake,

Thank you for providing those records. To be candid, we would like to speak to Officer Mullins regarding his observations that day.

As aforementioned, it is our understanding (thus far) that the Dearborn Police Officers who responded to the Saad residence did not play an active role in the events alleged in our Complaint. If this is indeed true, let us spare the City of Dearborn the time and expense of being involved in this litigation further.

I deem this is a reasonable request as well as a good-faith gesture to pursue and to obtain an expedient resolution to this matter (Mr. Mullins will be subject to questioning anyway during formal discovery).

If this is acceptable, kindly respond in the affirmative or contact me directly at either phone number provided below. We will stipulate to an extension for the CIty of Dearborn to file its Answer if needed.

Cordially,

Nick

On Thu, Jul 22, 2010 at 11:27 AM, Sabon-Ellerbrake, Laurie <lellerbrake@ci.dearborn.mi.us> wrote:

Mr. Hadous --

Thank-you for getting back with me so quickly -- I have been in
depositions so I just got your email this morning.

I have searched police records and have attached the only
documents in Dearborn's possession regarding the incident at issue.
Please review them and advise me as to how you wish to proceed.

My position remains the same. Discovery may lead to Plaintiffs
naming specific police officers in their lawsuit. However, as the
Complaint is pled right now, there is no cause of action against the
City of Dearborn. Thus, my request that the City of Dearborn be
dismissed from the case.

Thanks for your quick attention.

Laurie M. Ellerbrake
Deputy Corporation Counsel
City of Dearborn
13615 Michigan Avenue
Dearborn, Michigan 48126
313.943.2035
313.943.2469 (fax)
lellerbrake@ci.dearborn.mi.us

-----Original Message-----
From: legbizhub@msn.com [mailto:legbizhub@msn.com]
Sent: Thursday, July 22, 2010 11:19 AM
To: Sabon-Ellerbrake, Laurie
Subject: Attached image data

--
Nick N. Hadous
HADOUSCO. PLLC
Offices in Dearborn, MI and Scottsdale, AZ

Direct: 313.415.5559
Office: 313.846.6300
Fax: 313.846.6358
Email: nhadous@hadousco.com
www.hadousco.com

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