D'Angelo v. Clinton Township et al

Filing 14

MOTION for Leave to File Response to Plaintiff's Motion to Compel 7 by Clinton, Township of, Nicholas Dykas, Jason Figurski, Keith Watson. (Peacock, Peter)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION THOMAS D’ANGELO, Plaintiff, Case No. 2:10-c-12195 vs. Hon. Lawrence P. Zatkoff PAUL PARENT, CLINTON TOWNSHIP, a municipal entity, NICHOLAS DYKAS, JASON FIGURSKI and KEITH WATSON, in their official and individual capacities, jointly and severally, Magistrate Judge Mona Majzoub Removed from Macomb County Circuit Case No. 10-944-NO Defendants. ________________________________________________________________________________/ AMOS E. WILLIAMS (P39118) PETER W. PEACOCK (P37201) THOMAS E. KUHN (P37924) Plunkett Cooney Amos E. Williams, P.C. Attorneys for Defendants Clinton Township, Attorney for Plaintiff Dykas, Figurski and Watson 615 Griswold, Suite 1115 10 S. Main Street, Ste. 400 Detroit, MI 48226 Mt. Clemens, MI 48043 (313) 963-5222 (586) 466-7605 ________________________________________________________________________________/ DEFENDANTS CLINTON TOWNSHIP, NICHOLAS DYKAS, JASON FIGURSKI and KEITH WATSON’S MOTION FOR LEAVE TO FILE RESPONSE TO PLAINTIFF’S MOTION TO COMPEL DISCOVERY [7] NOW COME Defendants, CLINTON TOWNSHIP, NICHOLAS DYKAS, JASON FIGURSKI and KEITH WATSON (hereinafter referred to as “Defendant”), by and through their attorneys, Plunkett Cooney, and for their Motion for Leave to File Responses to Plaintiff’s Motion to Compel [7] states as follows: 1. 2010 [doc 7]. Plaintiff filed a Motion to Compel Against Defendants on or about August 31, 2. Defendant filed a Motion to Compel against Plaintiff on or about September 2, 3. Both Plaintiff and Defendants subsequently exchanged their respective 2010 [doc 10]. discovery responses leaving the pending motions moot. 4. Defendants anticipated that both Plaintiff and Defendants would file a Notice of Withdrawal of Motion and therefore did not timely response to Plaintiff’s Motion. 5. It now appears that Plaintiff is desirous to proceed with his Motion and treat it as a motion to compel more specific responses from Defendants, which the undersigned does not believe is proper. 6. Defendants have this date filed their Notice of Withdrawal of Motion [doc 13]. 7. As Plaintiff not dismissed his Motion to Compel, Defendants requests this Honorable Court grant leave for Defendants to file a Response to Plaintiff’s Motion to Compel. WHEREFORE, the above-named Defendants respectfully requests this Honorable Court allow Plaintiff to file a Response to Plaintiff’s Motion to Compel within 5 days upon entry of an Order. PLUNKETT COONEY BY: S/Peter W. Peacock___________________ PETER W. PEACOCK (P37201) Attorney for Clinton Township Defendants 10 S. Main, Suite 400 Mt. Clemens, MI 48043 Primary Email: ppeacock@plunkettcooney.com (586) 466-7605 Dated: October 7, 2010 2 PROOF OF SERVICE The undersigned certifies that on October 7, 2010 I electronically filed the foregoing pleading with the Clerk of the Court using ECF system which will send notification of such filing to the all attorneys of record of all parties in the above cause _s/Peter W. Peacock Open.01397.01593.10334595-1 Open.01397.01593.10334595-1 3

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