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Civil Rights: Other | Michigan Western
Certificate of Compliance Regarding Word Count
CERTIFICATE of compliance re word count for MOTION to compel Rule 30(b)(6) Deposition 206 filed by Ben Cabanaw, Susan Corbin, Poppy Sias Hernandez (Linderman Richelew, Marla)
Compel
MOTION to compel Rule 30(b)(6) Deposition by defendants Ben Cabanaw, Susan Corbin, Poppy Sias Hernandez; (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Transcript of Deposition of Tim Nolan & Janelle Brimers, dated 10/24/2025, # 3 Exhibit B - Re-Notice of Deposition of Plaintiffs Pursuant to Fed. R. Civ. P. 30(b)(6) Duces Tecum, dated 10/20/2025, # 4 Exhibit C - Defendants' email offering July & August Deposition dates, dated 7/13/2026, # 5 Exhibit D - Defendants' email offering July & August Deposition dates, dated 7/13/2026, # 6 Exhibit E - Plaintiffs email offering 8/25-8/27 dates, dated 7/21/2026, # 7 Exhibit F - Plaintiffs email offering 8/13 date, dated 7/30/2026, # 8 Exhibit G - Re-Notice of Deposition of Plaintiffs Pursuant to Fed. R. Civ. P. 30(b)(6) Duces Tecum, dated 8/4/2026, # 9 Exhibit H - Email Regarding Plaintiffs' First Written Objections, dated 8/11/2026; Attachment A - Written Objections, # 10 Exhibit I - Email Correspondence Offering Revised Topics & Plaintiffs' Rejection, dated 8/11-8/12/2026, # 11 Exhibit J - Deposition Transcript of Annie Osburn 30(b)(6) witness excerpts, dated 8/13/2026, # 12 Exhibit K - Deposition Transcript of Scott DeVries 30(b)(6) witness excerpts, dated 8/13/2026, # 13 Exhibit L - Email Correspondence regarding statement of faith, dated 11/28-12/4/2023, # 14 Exhibit M - Email with Proposed Compromise on 30(b)(6) Dispute, dated 8/21/2026) (Linderman Richelew, Marla)
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