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Act 41: Taubman Opposes
a Change of Venue (Take 2)

In addition to my motion to dismiss, the judge pointed out that my change of venue motion was also deficient. I refiled that motion, and Ms. Greenberg refiled her opposition.


UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THE TAUBMAN COMPANY LIMITED
PARTNERSHIP, a Delaware limited partnership,
Plaintiff,

v. WEBFEATS, a Texas company, and
HENRY MISHKOFF, an individual,
Defendants.

Case No. 01-72987
Hon. Lawrence P. Zatkoff


PLAINTIFF'S BRIEF OPPOSING (REVISED)
MOTION FOR CHANGE OF VENUE

Plaintiff incorporates by reference its original brief, filed in opposition to Defendants' original motion for change of venue, which did not comply in form with the local rules. A copy of Plaintiffs original brief is attached hereto for ease of reference.

Respectfully submitted,

Julie A. Greenberg (P-38299)
GIFFORD, KRASS, GROH, SPRINKLE,
ANDERSON & CITKOWSKI, P.C.
280 N. Old Woodward Ave., Suite 400
Birmingham, Michigan 48009-5394
248/647-6000

Attorneys for Plaintiff

Date: 11-29-01

View the Original Brief (in a separate window)


As she said, Ms. Greenberg attached a copy of her original response, which I'm not going to duplicate here. (You can find it elsewhere on this site.) Notice, however, that she was helpful enough to remind the judge that my original motion did not comply with local rules, in case that had slipped his mind.

Next: I Reply to Taubman's Allegation

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