Law Offices of David Yerushalmi, P.C. 

Washington Offices: Brooklyn, New York Offices: 

Center for Security Policy 640 Eastern Parkway 

1901 Pennsylvania Avenue NW Suite 4C 

Suite 201 Brooklyn, New York 11213 

Washington, D.C. 20006 

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Direct email: david.yerushalmi@verizon.net Woodland Hills, California 91364 

David Yerushalmi: Licensed in Washington, D.C., New York, California & Arizona 

 Of Counsel to the Institute for Advanced Strategic & Political Studies 

 General Counsel to the Center for Security Policy 

Gregory V. Bitterman: Licensed in New York & New Jersey 

February 1, 2010 

The Honorable Lawrence P. Zatkoff The Honorable Mona K. Majzoub 

United States District Judge United States Magistrate Judge

United States District Court, E.D. Michigan United States District Court, E.D. Michigan 

Federal Building Theodore Levin U.S. Courthouse 

200 E. Liberty Street 231 W. Lafayette 

Ann Arbor, Michigan 48104 Detroit, Michigan 48226 

Via Electronic Filing (ECF) 

Re: Murray v. Geithner et al., Case No: 08-15147/Motion to Compel 

Dear Judge Zatfkoff and Magistrate Judge Majzoub: 

On December 14, 2009, we filed a Motion to Compel the deposition of Defendant 

Geithner in the above-referenced matter on behalf of Plaintiff (Doc #31). On December 

21, 2009, the Court referred the Motion to the Honorable Mona K. Majzoub, United 

States Magistrate Judge (Doc #32). On December 29, the Court set an oral argument date 

of February 8, 2010 and a deadline of February 1 for the Joint Statement of Resolved and 

Unresolved Issues (Doc #34). 

The matter has been fully briefed. 

On January 28, 2010, the Court issued an order adjourning the oral argument on the 

motion and the filing of the Joint Statement without date (Doc #39). 
Letter to the Honorable Lawrence P. Zatkoff and Mona K. Majzoub 

February 1, 2010 

Subject: Murray v. Geithner et al., Case No: 08-15147/Motion to Compel 

Page 2 of 2 

Plaintiff intends to file a Motion to Compel on documents formally requested by Plaintiff 

and withheld by Defendants who have argued that Plaintiff’s document request is either 

not relevant or privileged. Plaintiff strongly disagrees with Defendants’ position. The 

parties’ counsel have made numerous efforts to resolve the matter without motion but 

there is a fundamental disagreement on the issues involved. 

However, in light of the Court’s recent order canceling both the oral argument and the 

Joint Statement without date on the Motion to Compel, Plaintiff seeks guidance from the 

Court since Plaintiff does not wish to burden the Court or to waste valuable resources 

filing a motion to compel that might be moot. We note, of course, that there are several 

motions pending, including Defendants’ Motion for Certificate of Appealability pursuant 

to 28 USC 1292(b) (Doc #20) and Plaintiff’s Motion for Leave to File First Amended 

Complaint (Doc #26), which might affect the pending Motion to Compel and our planned 

motion to compel. 

Thank you for the Court’s indulgence. 

Sincerely, 

LAW OFFICES OF DAVID YERUSHALMI, P.C. 

/s/ David Yerushalmi 

David Yerushalmi, Esq. 

THOMAS MORE LAW CENTER 

/s/ Robert J. Muise, Esq. 

CERTIFICATE OF SERVICE 

I hereby certify that on February 1, 2010, a copy of the foregoing Letter to the Honorable 

Lawrence P. Zatkoff and Mona K. Majzoub was filed electronically. Notice of this filing 

will be sent to all parties for whom counsel has entered an appearance by operation of the 

Court’s electronic filing system. Parties may access this filing through the Court’s 

system. I further certify that a copy of the foregoing has been served by ordinary U.S. 

mail upon all parties for whom counsel has not yet entered an appearance electronically: 

None. 

LAW OFFICES OF DAVID YERUSHAMI, P.C. 

/s/ David Yerushalmi 

David Yerushalmi, Esq.