Letters/Documents
related to the removal hearing |
|
Number |
Description
|
| 1
|
Letter
and attachments from William Goodman to the Governor hand delivering the
Petition and Charges of the Detroit City Council against Honorable Kwame
M. Kilpatrick Seeking his Removal for alleged Acts of Official Misconduct
(dated 5-20-08) |
|
|
Attached Documents
| Exhibit
A: |
Resolution
Seeking the Resignation of Mayor Kilpatrick, March 18, 2008
|
| Exhibit
B: |
Special Counsel's
Report, May 5, 2008 |
| Exhibit
C: |
Resolution
Censuring and Condemning the Conduct of Mayor, May 13, 2008
|
| Exhibit
D: |
Resolution
to Adopt the Special Counsel's Findings of Fact, May 13, 2008
|
| Exhibit
E: |
Transcript
of Detroit City Council Public Hearings on April 8, 2008
|
| Exhibit
F: |
Transcript
of Detroit City Council Public Hearings on April 10, 2008
|
| Exhibit
G: |
Transcript
of Detroit City Council Public Hearings on April 11, 2008
|
| Exhibit
H: |
Transcript
of Closed Session Minutes, September 19, 2007 |
| Exhibit
I: |
Plaintiffs'
Supplemental Brief in Support of Their Motion for Attorney Fees
and Costs (Micheal Stefani Brief) |
| Exhibit
J: |
Public
Hearing Documents Re: The Brown, Nelthrope, and Harris Settlements
& Related Matters |
| Exhibit
J #0 |
Public Hearing
Documents Re: The Brown, Nelthrope, and Harris Settlements &
Related Matters / Full version, April 2008 |
| Exhibit
J #1 |
Chronology
of Events |
| Exhibit
J #2 |
Summary of
the Michael Stefani Deposition |
| Exhibit
J #3 |
The First Settlement
Agreement of (Stefani Deposition Exhibit 11), October 17, 2007
|
| Exhibit
J #4 |
The Lawsuit
Settlement Memoranda |
| Exhibit
J #5 |
The Rejection
of the First Settlement Agreement (Stefani Deposition Exhibit
10), October 27, 2007 |
| Exhibit
J #6 |
The Notice
of Approval of the Settlement Agreement (Stefani Deposition Exhibit
9), November 01, 2007 |
| Exhibit
J #7 |
The Second
Settlement Agreement and General Release in the Brown and Nelthrope
Case |
| Exhibit
J #8 |
The Second
Settlement Agreement and General Release in the Harris Case
|
| Exhibit
J #9 |
The Confidentiality
Agreement (Stefani Deposition Exhibit 13), November 01, 2007
|
| Exhibit
J #10 |
The Escrow
Agreement (Stefani Deposition Exhibit 14) |
| Exhibit
J #11 |
The Supplement
to the Escrow Agreement (Stefani Deposition Exhibit 15)
|
| Exhibit
J #12 |
Notice of designation
of Mayor's Representative (Stefani Deposition Exhibit 8)
|
| Exhibit
J #13 |
The Free Press'
First FOIA request dated October 19, 2007 |
| Exhibit
J #14 |
The City of
Detroit's Response to the Free Press' First FOIA Request, October
29, 2007 |
| Exhibit
J #15 |
The Free Press'
Second FOIA Request, November 13, 2007 |
| Exhibit
J #16 |
The City of
Detroit's Response to the Free Press' Second FOIA Request, December
7, 2007 |
| Exhibit
J #17 |
Billing Records
from Grier, Copeland, & Williams in the Brown and Nelthrope
lawsuit |
| Exhibit
K: |
The Stefani
Hand-Written Notes |
| Exhibit
L: |
Transcript
of Hearing before Honorable Judge Colombo, February 05, 2008
|
|
| 2
|
Letter
from the Governor to Mayor Kwame Kilpatrick and Kenneth Cockrel regarding
designation of counsel (dated 5-21-08) |
| 3
|
Letter
from Kenneth Cockrel to Governor regarding Resolution passed by Detroit
City Council and notification that Goodman is counsel of record (dated
5-21-08) |
| 4
|
Letter
from William Goodman to John Johnson regarding Resolution (dated 5-21-08)
|
| 5
|
Letter
from William Goodman to Sharon McPhail regarding likelihood of being called
as a witness (dated 5-23-08) |
| 6
|
Letter
and attachments from Sharon McPhail regarding request by four members
of the Detroit City Council in opposition to request for removal (dated
5-28-08) |
| 7
|
(Revised)
Petition by Detroit City Council Members Opposing Removal (dated 6-2-08)
|
| 8
|
Letter
from Kelly Keenan to Sharon McPhail, William Goodman and James Thomas
regarding process (dated 6-3-08) |
| 9
|
Letter
to from William Goodman to Kelly Keenan regarding 6-3-08 letter (dated
6-11-08) |
| 10
|
Letter
from William Goodman to Kelly Keenan regarding Detroit City Council memorandum
(dated 6-11-08) |
| 11
|
Letter
from Kwame Kenyatta to Governor re response to dissenting petition (dated
6-11-08) |
| 12
|
Letter
from Kwame Kenyatta to Kelly Keenan re response to dissenting petition
(dated 6-11-08) |
| 13
|
Letter from Sharon
McPhail to Kelly Keenan in response to 6-3-08 letter (dated 6-23-08)
|
| 14
|
Letter from William
Goodman to Kelly Keenan in response to Sharon McPhail's 6-23-08 letter
(dated 7-1-08) |
| 15
|
Letter from Kelly Keenan
to Counsel re schedule (dated 7-1-08) |
| 16
|
Letter from William
Goodman to Kelly Keenan regarding his 7-1-08 letter (dated 7-2-08)
|
| 17
|
Letter from Kelly Keenan
to Counsel re accelerated schedule (dated 7-28-08) |
| 18
|
Letter
from Sharon McPhail to Kelly Keenan Requesting extension of time (dated
07-30-08) |
| 19
|
Order
Granting in Part Respondent's Request to Extend Schedule (dated 7-31-08)
|
| 20
|
Letter
from Sharon McPhail to Kelly Keenan in response to Willaim Goodman's 7-1-08
letter (dated 7-30-08) |
| 21
|
Letter
from David Whitaker to Sharon McPhail to advise of appointment to co-counsel
with William Goodman (dated 7-31-08) |
| 22
|
Petitioner
Detroit City Council's Motion for Hearing on the Merits in the Matter
of the Request for Removal of Kwame M. Kilpatrick and Brief in Support
(dated 8-6-08) |
| 23
|
Resondent's
Motion to Dismiss the Petition of Detroit City Council... and Memorandum
in Support of Motion... (dated 8-6-08) |
| 24
|
List
of Exhibits to Respondent's Motion to Dismiss the Petition of Detroit
City Council (dated 8-6-08)
|
| 25
|
Corrected
Memorandum of Respondent, Kwame M. Kilpatrick, in Support... (dated 8-7-08)
|
| 26
|
Notice
of Hearing (dated 8-7-08) |
| 27
|
Letter
from Kenneth Cockrel designating David Whitaker as co-counsel (dated 8-6-08)
|
| 28
|
Letter
from Sharon McPhail responding to Governor's Notice of Hearing (dated
8-8-08) |
| 29
|
Letter
from William Goodman responding to Sharon McPhail's 8-7-08 and 8-8-08
letters (dated 8-8-08) |
| 30
|
Letter
from Kelly Keenan to Counsel in response to Sharon McPhail's 8-8-08 letter
(dated 8-8-08) |
| 31
|
Prehearing Order (dated
8-11-08) |
| 32
|
Letter
from Sharon McPhail regarding response to William Goodman's letter dated
8-8-08 (dated 8-11-08) |
| 33
|
Letter
from Kelly Keenan to Counsel responding to a portion of Sharon McPhail's
8-8-08 letter (dated 8-12-08) |
| 34
|
Letter
from Sharon McPhail in response to Kelly Keenan's 8-12-08 letter (dated
8-13-08) |
| 35
|
Letter
from William Goodman in response to Sharon McPhail's 8-13-08 letter (dated
8-13-08) |
| 36
|
Letter
from Kelly Keenan to Counsel in response to Sharon McPhail's 8-13-08 letter
(dated 8-14-08) |
| 37
|
Letter
from Sharon McPhail regarding immunity issue (dated 8-14-08)
|
| 38
|
Letter
from William Goodman in response to Sharon McPhail's 8-13-08 letter (dated
8-15-08) |
| 39
|
Letter
from Sharon McPhail in response to William Goodman's 8-15-08 letter (dated
8-15-08) |
| 40
|
Letter
from William Goodman in response to Sharon McPhail's August 15, 2008 letter
(dated 8-15-08) |
| 41
|
Petitioner's Witness
List and Exhibits (Exhibits to be posted) (dated 8-15-08)
|
| 42
|
Letter
from Sharon McPhail with a request for production of documents (dated
8-15-08) |
| 43
|
Letter
from William Goodman with a request for production of documents (dated
8-15-08) |
| 44
|
Letter
from William Goodman regarding a supplemental witness list (dated 8-16-08)
|
| 45
|
Index of Exhibits
of Petitioner
|
| 46
|
Letter from Sharon
McPhail regarding Council Forfeiture Hearings Will Not be Held (dated
8-18-08) |
| 47
|
Letter
from William Goodman regarding Sharon McPhail's 8-18-08 letter (dated
8-18-08) |
| 48
|
Letter
from Sharon McPhail in response to William Goodman's 8-18-08 letter (dated
8-20-08) |
| 49
|
Petitioner Detroit
City Council's Response to Respondent Mayor Kilpatrick's Motion to Dismiss
the Petition of the Detroit City Council or, in the Alternative, to Stay
the Proceedings (dated 8-20-08) |
| 50
|
Respondent's Memorandum
in Response & in Opposition to Petitioner's Motion for a Hearing
on the Merits of the Petition of the Detroit City Council for the Removal
of Mayor from Office (dated 8-20-08)
|
| 51
|
Petitioner's Second
Supplemental Witness List and Brief Description of Proposed Testimony
of Said Witness (dated 8-21-08) |
| 52
|
Letter from William
Goodman submitting errata list to Response to Petitioners Motion to Dismiss
(dated 8-22-08) |
| 53
|
Letter from William
Goodman correcting errata list to Response to Petitioners Motion to Dismiss
(dated 8-22-08) |
| 54
|
Council's Reply to
Respondent's Response in Opposition to Petitioner's Motion for a Hearing
on the Merits (dated 8-25-08) |
| 55
|
Letter from Kelly Keenan
to Sharon McPhail regarding filing of exhibits, witness list and reply
brief (dated 8-25-08) |
| 56
|
Respondent, Kwame
M. Kilpatrick's Reply to Petitioner's Pleadings Pursuant to Prehearing
Order of August 11, 2008 (dated 8-25-08)
|
| 57
|
Opinion
and Order (1) Denying Respondent's Motion to Dismiss Petition or Stay
Proceedings and (2) Granting Petitioner's Motion for Hearing on the Merits
(dated 8-25-08) |
| 58
|
Notice
of Prehearing Conference (dated 8-25-08) |
| 59
|
Order
Designating Special Administrative Hearing Assistant (dated 8-25-08)
|
| 60
|
Respondent's Supplemental
Witness List (dated 8-27-08) |
| 61
|
Letter
from Sharon McPhail to Kelly Keenan regarding refusal of witnesses to
appear (dated 8-27-08) |
| 62 |
Petitioner's
Supplemental Exhibit List (dated 8-28-08) |
| 63 |
Memorandum
from Sharon McPhail to Counsel regarding Petitioner's Supplemental Exhibit
List (dated 8-28-08) |
| 64 |
Opinion
and Order Addressing Legal Issues Raised by Respondent in Pre-hearing
Correspondence (dated 9-2-08) |
| 65 |
Supplemental
Prehearing Order (dated 9-2-08) |
| 66 |
Letter
from Sharon McPhail to Kelly Keenan regarding Opinion and Order (received
9-2-08) |
| 67 |
Governor
Granholm's Statement from the Bench (dated 9-4-08) |
| |
|
Documents
related to legal challenge filled in Michigan state courts, Hon. Kwame
M. Kilpatrick v. Hon. Jennifer M. Granholm |
Wayne
County |
| 1 |
Complaint
for Injunctive and Declaratory Relief and Notice of Hearing (dated 8-28-08)
|
| 2 |
Governor's
Memorandum of Law in Opposition to Plaintiff's Emergency Motion for Temporary
Restraining Order and Preliminary Injunction, Attachments and Appearance
(dated 8-29-08) |
| 3 |
Detroit
City Council's Opposition to Plaintiff's Motion for a Temporary Restraining
Order and Preliminary Injunction (dated 8-29-08) |
| 4 |
Second
Supplemental Memorandum of Law in Support of Plaintiff's Emergency Motion
for Temporary Restraining Order and Preliminary Injunction (dated 8-29-08) |
| 5 |
Affidavit
of Governor Jennifer M. Granholm (dated 9-1-08) |
| 6 |
Governor's
Motion to Strike Affidavit of James C. Thomas (dated 9-2-08) |
| 7 |
Brief
in Support of Governor's Motion to strike Affidavit of James C. Thomas
(dated 9-2-08) |
| 8 |
Notice
of Filing Application for Leave to Appeal with Michigan Supreme Court
(dated 9-3-08) |
Michigan
Court of Appeals |
| 1 |
Claim
of Appeal (dated 9-2-08) |
| 2 |
Motion
for Expedited Hearing (dated 9-2-08) |
| 3 |
Plaintiff-Appellant's
Brief on Appeal (dated 9-2-08) |
| 4 |
Motion
to Stay Proceedings (dated 9-2-08) |
| 5 |
Motion
for Immediate Consideration of Motion to Stay Proceedings (dated 9-2-08) |
| 6 |
Proof
of Service (dated 9-2-08) |
| 7 |
Order
(dated 9-2-08) |
| 8 |
Motion
to Waive Transcript Filing Requirement Pursuant to MCR 7.209(A)(3) (dated
9-2-08) |
| 9 |
Notice
of Filing Application for Leave to Appeal with Michigan Supreme Court
(dated 9-3-08) |
Michigan
Supreme Court |
| 1 |
Executive
Message of Governor Jennifer M. Granholm (dated 9-2-08) |
| 2 |
Emergency
Application for Leave to Appeal (dated 9-3-08) |
| 3 |
Motion
for Immediate Consideration of Pending Application for Leave to Appeal
(dated 9-3-08) |
| 4 |
Motion
for Immediate Consideration of Motion to Stay Proceedings (dated 9-3-08) |
| 5 |
Motion
to Stay Proceedings (dated 9-3-08) |
| 6 |
Notice
of Hearing (Motion to Stay Proceedings) (dated 9-3-08) |
| 7 |
Notice
of Hearing (Application for Leave to Appeal) (dated 9-3-08) |
| 8 |
Proof
of Service (dated 9-3-08) |
| 9 |
Order
(regarding Governor's Executive Message) (dated 9-4-08) |
| 10 |
Order
(regarding Plaintiff-Appellant's filings) (dated 9-4-08) |
| |
|
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