Flagg v. Detroit, City of et al

Filing 125

F l a g g v. Detroit, City of et al

D o c . 125

UNITED STATES DISTRICT COURT E A S T E R N DISTRICT OF MICHIGAN S O U T H E R N DIVISION E R N E S T FLAGG, as Next Friend o f JONATHAN BOND, P l a in tif f , vs. C IT Y OF DETROIT, et al, D e f e n d a n ts . ______________________________/ C a se No. 05-74253 H O N . GERALD E. ROSEN

N O T I C E PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE RULE 26(b)(5)

N O W COMES defendant, Kwame M. Kilpatrick, by and through his counsel, JAMES C. T H O M A S , of counsel to PLUNKETT COONEY, and gives notice that pursuant to F.R.Civ.P., Rule 2 6 (b )(5 ), defendant Kilpatrick claims privilege as it relates to any communications, whether oral or w ritten , by and between himself and proposed deponent William Mitchell III, as well as any work p ro d u c t that may have been generated as a result of the attorney/client relationship. Respectfully submitted, P L U N K E T T COONEY /s/ James C. Thomas J a m e s C. Thomas P23801 A tto rn e y for Kilpatrick S u ite 2632, 535 Griswold Street D e tro it, MI 48226 3 1 3 -9 6 3 -2 4 2 0 j t h o m a s @ p l u n k e t t c o o n e y. c o m D A T E D : July 28, 2008

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CERTIFICATE OF SERVICE I hereby certify that on July 28, 2008, I electronically filed the foregoing paper with the Clerk o f the Court using the ECF system which will send notification of such filing to all counsel of r e c o rd .

/s/ James C. Thomas J a m e s C. Thomas