IN THE STATE OF MICHIGAN

IN THE 14th CIRCUIT COURT FOR THE COUNTY OF MUSKEGON

DANIEL W. RUDD,
Plaintiff, File No. 2017-004334-CZ
Honorable Timothy G. Hicks
v.
Plaintiffs Motion RE: Adjournment &
CITY OF NORTON SHORES, Request For Description of Records
Defendant.

Daniel W. Rudd Michael S. Bogren & Lisa A. Hall (Grand Rapids)

P l a i n t i f f , P r o S e P l u n k e t t C o o n e y, P. C . f o r D e f e n d a n t
201 S Lake Ave 950 Trade Centre Way, Suite 310
Spring Lake, MI 49456 Kalamazoo, Michigan 49002
(231) 557-2532 (269) 226-8822 & (616)752-4615
daniel@stock20.com mbogren@plunkettcooney.com lhall@plunkettcooney.com

PLAINTIFF'S MOTION OPPOSING ADJOURNMENT OF BENCH TRIAL

& AND SEEKING AN ORDER COMPELLING DETAILED DESCRIPTIONS
OF RECORDS WITHELD AND PARTICULARIZED BASIS FOR NON-DISCLOSURE

For the reasons stated in his supporting brief, Plaintiff seeks the following relief:

1) This Court should deny Defendant's motion to adjourn the bench trial which is
currently set for 4/5/2018.

2) Defendant should present the identified witnesses for examination during the
3/12/2018 motion hearing.

3) At a minimum Defendant should be required to identify the nature of the testimony to

be presented and the relevance of that testimony to the disputed issues.

4) The 4/5/2018 bench trial should proceed as scheduled. The issue of records
disclosure may be resolved without further testimony from witnesses.

5) This Court should issue an order which compelling Defendant to file and serve an
affidavit which meets the standards set forth by the Michigan Supreme Court in Evening News
Ass'n v. City of Troy, 417 Mich. 481, 503, 339 N.W.2d 421 (1983).

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6) Plaintiff will present a proposed order at the 3/12/2018 hearing and respectfully
submits these requests, along with his supporting brief, for this Court's consideration.

Respectfully Submitted on 2/28/2018:

Daniel W. Rudd, Plaintiff (Pro Se)
201 S LAKE AVE, SPRING LAKE, MI 49456
(231) 557-2532 daniel@stock20.com

PROOF OF SERVICE: The undersigned certifies that a copy of the foregoing document was served
on counsel for Defendant by (1) email attachment to the addresses noted in the caption, & (2) Via U.S.
mail to the address noted in the caption above, with postage fully prepaid, on 2/28/2018.

^ ^M: \y \ K^M ^p»(/6 Daniei w Rudd> piaintiff (Pro Se)

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