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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.

©2001 Hank Mishkoff
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