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Documents Regarding the Honorable Kwame M. Kilpatrick

This site includes documents that have been received or sent by the Office of the Governor regarding the Detroit City Council petition.

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Letters/Documents

Number Description
1 Letter and attachments from William Goodman to the Governor hand delivering the Petition and Charges of the Detroit City Council against Honorable Kwame M. Kilpatrick Seeking his Removal for alleged Acts of Official Misconduct (dated 5-20-08)
  Attached Documents
Exhibit A: Resolution Seeking the Resignation of Mayor Kilpatrick, March 18, 2008
Exhibit B: Special Counsel's Report, May 5, 2008
Exhibit C: Resolution Censuring and Condemning the Conduct of Mayor, May 13, 2008
Exhibit D: Resolution to Adopt the Special Counsel's Findings of Fact, May 13, 2008
Exhibit E: Transcript of Detroit City Council Public Hearings on April 8, 2008
Exhibit F: Transcript of Detroit City Council Public Hearings on April 10, 2008
Exhibit G: Transcript of Detroit City Council Public Hearings on April 11, 2008
Exhibit H: Transcript of Closed Session Minutes, September 19, 2007
Exhibit I: Plaintiffs' Supplemental Brief in Support of Their Motion for Attorney Fees and Costs (Micheal Stefani Brief)
Exhibit J: Public Hearing Documents Re: The Brown, Nelthrope, and Harris Settlements & Related Matters
Exhibit J #0 Public Hearing Documents Re: The Brown, Nelthrope, and Harris Settlements & Related Matters / Full version, April 2008
Exhibit J #1 Chronology of Events
Exhibit J #2 Summary of the Michael Stefani Deposition
Exhibit J #3 The First Settlement Agreement of (Stefani Deposition Exhibit 11), October 17, 2007
Exhibit J #4 The Lawsuit Settlement Memoranda
Exhibit J #5 The Rejection of the First Settlement Agreement (Stefani Deposition Exhibit 10), October 27, 2007
Exhibit J #6 The Notice of Approval of the Settlement Agreement (Stefani Deposition Exhibit 9), November 01, 2007
Exhibit J #7 The Second Settlement Agreement and General Release in the Brown and Nelthrope Case
Exhibit J #8 The Second Settlement Agreement and General Release in the Harris Case
Exhibit J #9 The Confidentiality Agreement (Stefani Deposition Exhibit 13), November 01, 2007
Exhibit J #10 The Escrow Agreement (Stefani Deposition Exhibit 14)
Exhibit J #11 The Supplement to the Escrow Agreement (Stefani Deposition Exhibit 15)
Exhibit J #12 Notice of designation of Mayor's Representative (Stefani Deposition Exhibit 8)
Exhibit J #13 The Free Press' First FOIA request dated October 19, 2007
Exhibit J #14 The City of Detroit's Response to the Free Press' First FOIA Request, October 29, 2007
Exhibit J #15 The Free Press' Second FOIA Request, November 13, 2007
Exhibit J #16 The City of Detroit's Response to the Free Press' Second FOIA Request, December 7, 2007
Exhibit J #17 Billing Records from Grier, Copeland, & Williams in the Brown and Nelthrope lawsuit
Exhibit K: The Stefani Hand-Written Notes
Exhibit L: Transcript of Hearing before Honorable Judge Colombo, February 05, 2008
2 Letter from the Governor to Mayor Kwame Kilpatrick and Kenneth Cockrel regarding designation of counsel (dated 5-21-08)
3 Letter from Kenneth Cockrel to Governor regarding Resolution passed by Detroit City Council and notification that Goodman is counsel of record (dated 5-21-08)
4 Letter from William Goodman to John Johnson regarding Resolution (dated 5-21-08)
5 Letter from William Goodman to Sharon McPhail regarding likelihood of being called as a witness (dated 5-23-08)
6 Letter and attachments from Sharon McPhail regarding request by four members of the Detroit City Council in opposition to request for removal (dated 5-28-08)
7 (Revised) Petition by Detroit City Council Members Opposing Removal (dated 6-2-08)
8 Letter from Kelly Keenan to Sharon McPhail, William Goodman and James Thomas regarding process (dated 6-3-08)
9 Letter to from William Goodman to Kelly Keenan regarding 6-3-08 letter (dated 6-11-08)
10 Letter from William Goodman to Kelly Keenan regarding Detroit City Council memorandum (dated 6-11-08)
11 Letter from Kwame Kenyatta to Governor re response to dissenting petition (dated 6-11-08)
12 Letter from Kwame Kenyatta to Kelly Keenan re response to dissenting petition (dated 6-11-08)
13 Letter from Sharon McPhail to Kelly Keenan in response to 6-3-08 letter (dated 6-23-08)
14 Letter from William Goodman to Kelly Keenan in response to Sharon McPhail's 6-23-08 letter (dated 7-1-08)
15 Letter from Kelly Keenan to Counsel re schedule (dated 7-1-08)
16 Letter from William Goodman to Kelly Keenan regarding his 7-1-08 letter (dated 7-2-08)
17 Letter from Kelly Keenan to Counsel re accelerated schedule (dated 7-28-08)
18 Letter from Sharon McPhail to Kelly Keenan Requesting extension of time (dated 07-30-08)
19 Order Granting in Part Respondent's Request to Extend Schedule (dated 7-31-08)
20 Letter from Sharon McPhail to Kelly Keenan in response to Willaim Goodman's 7-1-08 letter (dated 7-30-08)
21 Letter from David Whitaker to Sharon McPhail to advise of appointment to co-counsel with William Goodman (dated 7-31-08)
22 Petitioner Detroit City Council's Motion for Hearing on the Merits in the Matter of the Request for Removal of Kwame M. Kilpatrick and Brief in Support (dated 8-6-08)
23 Resondent's Motion to Dismiss the Petition of Detroit City Council... and Memorandum in Support of Motion... (dated 8-6-08)
24

List of Exhibits to Respondent's Motion to Dismiss the Petition of Detroit City Council (dated 8-6-08)

 25   Corrected Memorandum of Respondent, Kwame M. Kilpatrick, in Support... (dated 8-7-08)
26  Notice of Hearing (dated 8-7-08)
27 Letter from Kenneth Cockrel designating David Whitaker as co-counsel (dated 8-6-08)
28 Letter from Sharon McPhail responding to Governor's Notice of Hearing (dated 8-8-08)
29 Letter from William Goodman responding to Sharon McPhail's 8-7-08 and 8-8-08 letters (dated 8-8-08)
30 Letter from Kelly Keenan to Counsel in response to Sharon McPhail's 8-8-08 letter (dated 8-8-08)
31 Prehearing Order (dated 8-11-08)
32 Letter from Sharon McPhail regarding response to William Goodman's letter dated 8-8-08 (dated 8-11-08)
33 Letter from Kelly Keenan to Counsel responding to a portion of Sharon McPhail's 8-8-08 letter (dated 8-12-08)
34 Letter from Sharon McPhail in response to Kelly Keenan's 8-12-08 letter (dated 8-13-08)
35 Letter from William Goodman in response to Sharon McPhail's 8-13-08 letter (dated 8-13-08)
36 Letter from Kelly Keenan to Counsel in response to Sharon McPhail's 8-13-08 letter (dated 8-14-08)
37 Letter from Sharon McPhail regarding immunity issue (dated 8-14-08)
38 Letter from William Goodman in response to Sharon McPhail's 8-13-08 letter (dated 8-15-08)
39 Letter from Sharon McPhail in response to William Goodman's 8-15-08 letter (dated 8-15-08)
40 Letter from William Goodman in response to Sharon McPhail's August 15, 2008 letter (dated 8-15-08)
41 Petitioner's Witness List and Exhibits (Exhibits to be posted) (dated 8-15-08)
42 Letter from Sharon McPhail with a request for production of documents (dated 8-15-08)
43 Letter from William Goodman with a request for production of documents (dated 8-15-08)
44 Letter from William Goodman regarding a supplemental witness list (dated 8-16-08)
45

Index of Exhibits of Petitioner

46 Letter from Sharon McPhail regarding Council Forfeiture Hearings Will Not be Held (dated 8-18-08)
47 Letter from William Goodman regarding Sharon McPhail's 8-18-08 letter (dated 8-18-08)
48 Letter from Sharon McPhail in response to William Goodman's 8-18-08 letter (dated 8-20-08)
49 Petitioner Detroit City Council's Response to Respondent Mayor Kilpatrick's Motion to Dismiss the Petition of the Detroit City Council or, in the Alternative, to Stay the Proceedings (dated 8-20-08)
50

Respondent's Memorandum in Response & in Opposition to Petitioner's Motion for a Hearing on the Merits of the Petition of the Detroit City Council for the Removal of Mayor from Office (dated 8-20-08)

51 Petitioner's Second Supplemental Witness List and Brief Description of Proposed Testimony of Said Witness (dated 8-21-08)
52 Letter from William Goodman submitting errata list to Response to Petitioners Motion to Dismiss (dated 8-22-08)
53 Letter from William Goodman correcting errata list to Response to Petitioners Motion to Dismiss (dated 8-22-08)
54 Council's Reply to Respondent's Response in Opposition to Petitioner's Motion for a Hearing on the Merits (dated 8-25-08)
 55 Letter from Kelly Keenan to Sharon McPhail regarding filing of exhibits, witness list and reply brief (dated 8-25-08)
 56

Respondent, Kwame M. Kilpatrick's Reply to Petitioner's Pleadings Pursuant to Prehearing Order of August 11, 2008 (dated 8-25-08)

57 Opinion and Order (1) Denying Respondent's Motion to Dismiss Petition or Stay Proceedings and (2) Granting Petitioner's Motion for Hearing on the Merits (dated 8-25-08)
58 Notice of Prehearing Conference (dated 8-25-08)
59 Order Designating Special Administrative Hearing Assistant (dated 8-25-08)
60 Respondent's Supplemental Witness List (dated 8-27-08)
61 Letter from Sharon McPhail to Kelly Keenan regarding refusal of witnesses to appear (dated 8-27-08)
62 Complaint for Injunctive and Declaratory Relief and Notice of Hearing (dated 8-28-08)
 63 Petitioner's Supplemental Exhibit List (dated 8-28-08)
64 Governor's Memorandum of Law in Opposition to Plaintiff's Emergency Motion for Temporary Restraining Order and Preliminary Injunction, Attachments and Appearance (dated 8-29-08)
65 Memorandum from Sharon McPhail to Counsel regarding Petitioner's Supplemental Exhibit List (dated 8-28-08)
 66 Detroit City Council's Opposition to Plaintiff's Motion for a Temporary Restraining Order and Preliminary Injunction (dated 8-29-08)


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