Académique Documents
Professionnel Documents
Culture Documents
235 Page 1 of 16
1
3 SOUTHERN DIVISION
6 vs.
8 Defendants.
9
Before:
10
THE HONORABLE JANET NEFF,
11 U.S. District Judge
Grand Rapids, Michigan
12 Thursday, February 9, 2017
Premotion Conference Proceedings
13
APPEARANCES:
14
MR. MICHAEL A. COX
15 The Mike Cox Law Firm, PLLC
17430 Laurel Park Dr., N
16 Suite 120E
Livonia, MI 48152
17 734-591-4002
25
Case 1:16-cv-01116-JTN-ESC ECF No. 61 filed 02/13/17 PageID.236 Page 2 of 16
2
1
MR. MICHAEL S. BOGREN
2 Plunkett Cooney
950 Trade Centre Way
3 Suite 310
Kalamazoo, MI 49002
4 269-226-8822
23
24
25
Case 1:16-cv-01116-JTN-ESC ECF No. 61 filed 02/13/17 PageID.237 Page 3 of 16
3
1
MR. TODD J. OHLMS
2 Freeborn & Peters
311 South Wacker Drive
3 Suite 3000
Chicago, IL 60606
4 312-360-6000
10
11
12
13
14
15
16
REPORTED BY: MS. KATHY J. ANDERSON, RPR, FCRR
17
18
19
20
21
22
23
24
25
Case 1:16-cv-01116-JTN-ESC ECF No. 61 filed 02/13/17 PageID.238 Page 4 of 16
4
1 February 9, 2017
6 everybody.
8 THE COURT: This is the date and time set for hearing
15 Companies, LLC.
22 up so that I can hear you clearly, and that the court reporter
7 Virg Bernero.
12 THE COURT: And who are -- Mr. Pacific, who are you
13 here for?
1 Mr. Bogren, I'm not too sure I have seen any of the others of
3 speak, would you please state your name again so that the court
17 Bernero.
19 here based on my law clerk's memo, but one of the things you
22 claims, et cetera. And then you say, "And the plaintiffs were
18 of the courtroom. Now, Mr. Cox, are you the drafter of the
19 complaint?
9 connection between the case and the paragraph. And, you know,
15 you kept saying that Mr. Ferguson has a lot of political power.
23 claims that you attempt to raise, what they don't do is set out
6 and God knows I love creative lawyers, who came up with the
14 language you used to impugn her integrity, but that his, his
16 and belief. I mean how the heck do you answer something like
18 have?
21 because I know what I'm going to get. And with five of them, I
24 and they are very good, and they are good drafters, and they
1 what I'm going to get from them and what you're going to get
15 first one. So I gave up. But I'm not going to give up here.
3 that. But I just can't believe that you would have filed this.
6 plead and prove a RICO claim. And I'm sort of giving you a do
12 should delineate each defendant and what exactly they did that
17 You've got the two RICO claims, you've got a Fourth Amendment
18 due process claim, then you've got the two business, tortious
5 pleading.
7 guess it sort of turned out that way. But I've already spent
8 so much time with your complaint and trying to figure out what
11 opportunity to do it.
16 a way that complies with the statute and the case law. And
17 once you have done that, then I'm going to ask defense counsel
18 to, I'm going to give you 14 days to do it, I'm going to ask
9 more days?
14 March?
24 afternoon?
6 thank you. I'll look forward to hearing from you further and
15 today or tomorrow.
18 think March 9th was the date that you used, I believe you said
20 only suggest that the first week of April not be used for
23 grandchildren.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:16-cv-01116-JTN-ESC ECF No. 61 filed 02/13/17 PageID.250 Page 16 of 16
16
1 REPORTER'S CERTIFICATE
11 direction.
12
13
19
20
21
22
23
24
25