Well written! Haytham Faraj 760-521-7934 Sent from my iPhone Ms. Ellerbrake:
As you know, our Complaint is directed primarily at the City of Dearborn Heights, the Dearborn Heights Police Department, and Dearborn Heights officers (the "Dearborn Heights Defendants"). Allegations which could have been made and which can still be made against the City of Dearborn, the Dearborn Police Department, and the John Doe officers (the "Dearborn Defendants") have been withheld (for our own reasons).
We would be willing to consider dismissing the City of Dearborn and the Dearborn Police Department if given the opportunity to conduct minor informal discovery regarding the events alleged in our Complaint (i.e., to question the Dearborn police officers who were present). If after questioning the Dearborn officers who were present we are satisfied that they played no active/significant role and if the officers otherwise respond in good-faith to our queries, we would likely dismiss the Dearborn Defendants.
If this is acceptable to you, let us schedule a conference call for tomorrow afternoon with Mr. Faraj. Otherwise, we will proceed accordingly.
Cordially,
Nick Hadous
On Fri, Jul 16, 2010 at 10:33 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote:
Dear Ms. Sabon-Ellerbrake:
We are in receipt of your letter. Mr. Hadous and I will give
serious consideration to your argument. You can expect to hear back from
us early next week.
Sincerely,
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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