UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

SOUTHWEST METALS Inc., a 

Michigan corporation, and JOSEPH FAWAZ, 

an individual, 

Plaintiffs, 

v. Case No.: 15-CV-11080 

 Hon. Marianne O. Battani 

 Mag. Anthony P. Patti 

CITY OF DETROIT, MICHAEL E. 

DUGGAN, Mayor of Detroit, in his 

official capacity, DETROIT POLICE 

DEPARTMENT, JAMES CRAIG, 

Detroit Police Chief, in his official 

capacity, SGT. REBECCA McKAY in 

her individual and official capacities, 

KEVIN JONES, City of Detroit 

Business License Center Manager, in 

his official capacity, CITY OF 

DETROIT BUSINESS LICENSE 

CENTER, jointly and severally.

 

Defendants. 

AYAD LAW, PLLC CITY OF DETROIT LAW DEPARTMENT 

NABIH H. AYAD (P59518) ERIC B. GAABO (P39213) 

Attorney for Plaintiffs Attorney for Defendant City of Detroit 

645 Griswold St., Ste. 2202 Coleman A. Young Municipal Center 

Detroit, MI 48226 2 Woodward Avenue, Suite 500 

Phone: (313) 983-4600 Detroit, MI 48226 

Fax: (313) 983-4665 (313) 237-5052 

Email: nayad@ayadlaw.com gaabe@detroitmi.gov 

 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1096 Filed 10/27/16 Page 1 of 7
STIPULATION TO ADJOURN STATUS CONFERENCE AND EXTEND 

DISPOSITIVE MOTION CUTOFF DATE 

IT IS HEREBY STIPULATED, by and between both parties, by and 

through their respective counsel, that: 

1. There is currently a status conference set for October 27, 2016 at 4:00 

p.m. 

2. The cutoff date for Dispositive Motions in this matter is October 27, 

2016. 

3. Counsel for the Parties are making good-faith efforts to resolve this 

matter, and an adjournment will aid in the resolution of this matter. 

4. That due to ongoing settlement discussions between the parties, an 

adjournment of the status conference set for October 27, 2016 to 

November 23, 2016 at 4:00 p.m. is appropriate and an extension of the 

Dispositive Motion cutoff date from October 27, 2016 to December 15, 

2016 is appropriate. 

WHEREFORE, the parties request the following relief: 

1. The status conference currently set for October 27, 2016 is adjourned to 

November 23, 2016 at 4:00 p.m.; and 

2. The Dispositive Motion cutoff date shall be extended to December 15,, 

2016. 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1097 Filed 10/27/16 Page 2 of 7
_/s/ Nabih H. Ayad_________ /s/ Eric Gaabo (w/ consent)_____ 

Nabih Ayad Eric Gaabo 

645 Griswold St., Ste. 2202 Coleman A. Young Municipal Center 

Detroit, MI 48226 2 Woodward Avenue, Suite 500 

Phone: (313) 983-4600 Detroit, MI 48226 

Fax: (313) 983-4665 (313) 237-5052 

Email: nayad@ayadlaw.com gaabe@detroitmi.gov 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1098 Filed 10/27/16 Page 3 of 7
CERTIFICATE OF SERVICE 

I hereby certify that on October 26, 2016, I e-mailed the foregoing stipulation to 

Eric Gaabo at gaabe@detroitmi.gov. 

Respectfully Submitted, 

Dated: October 26, 2016 /s/ Nabih H. Ayad 

Nabih H. Ayad 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1099 Filed 10/27/16 Page 4 of 7
UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

SOUTHWEST METALS Inc., a 

Michigan corporation, and JOSEPH FAWAZ, 

an individual, 

Plaintiffs, 

v. Case No.: 15-CV-11080 

 Hon. Marianne O. Battani 

 Mag. Anthony P. Patti 

CITY OF DETROIT, MICHAEL E. 

DUGGAN, Mayor of Detroit, in his 

official capacity, DETROIT POLICE 

DEPARTMENT, JAMES CRAIG, 

Detroit Police Chief, in his official 

capacity, SGT. REBECCA McKAY in 

her individual and official capacities, 

KEVIN JONES, City of Detroit 

Business License Center Manager, in 

his official capacity, CITY OF 

DETROIT BUSINESS LICENSE 

CENTER, jointly and severally.

 

Defendants. 

AYAD LAW, PLLC CITY OF DETROIT LAW DEPARTMENT 

NABIH H. AYAD (P59518) ERIC B. GAABO (P39213) 

Attorney for Plaintiffs Attorney for Defendant City of Detroit 

645 Griswold St., Ste. 2202 Coleman A. Young Municipal Center 

 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1100 Filed 10/27/16 Page 5 of 7
Detroit, MI 48226 2 Woodward Avenue, Suite 500 

Phone: (313) 983-4600 Detroit, MI 48226 

Fax: (313) 983-4665 (313) 237-5052 

Email: nayad@ayadlaw.com gaabe@detroitmi.gov 

STIPULATED ORDER 

The parties, by and through their respective counsel, stipulate and agree to 

adjourn the status conference currently set for October 27, 2016 to November 23, 

2016 at 4:00 p.m., and extend the dispositive motion cutoff date from October 27, 

2016 to December 15, 2016, due to ongoing settlement discussions. Counsel for 

the Parties are making good-faith efforts to conduct discovery, and an adjournment 

will aid in the resolution of this matter.

The Court having considered the stipulation of the parties, and this Court 

being otherwise fully advised, HEREBY ORDERS that: 

3. The status conference currently set for October 27, 2016 is adjourned to 

November 29, 2016 at 4:00 p.m.; and 

4. Dispositive Motions shall be filed by December 15,, 2016. 

Dated: October 27, 2016 s/Anthony P. Patti 

Mag. Anthony P. Patti 

_/s/ Nabih H. Ayad_________ /s/ Eric Gaabo (w/ consent)_____ 

Nabih Ayad Eric Gaabo 

645 Griswold St., Ste. 2202 Coleman A. Young Municipal Center 

Detroit, MI 48226 2 Woodward Avenue, Suite 500 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1101 Filed 10/27/16 Page 6 of 7
Phone: (313) 983-4600 Detroit, MI 48226 

Fax: (313) 983-4665 (313) 237-5052 

Email: nayad@ayadlaw.com gaabe@detroitmi.gov 

Case 2:15-cv-11080-MOB-APP ECF No. 63, PageID.1102 Filed 10/27/16 Page 7 of 7