BEVERLY TRAN

September 28, 2015

August Gitschlag, City Clerk

City of Hamtramck
3401 Evaline
Hamtramck, MI 48212

RE: FOIA REQUEST

Dear Mr. Gitschlag:

Pursuant to the Michigan Freedom of Information Act, MCL 15.231 et seq, this is
to request the following information/documentation:

Request # (i) Copies of any and all written instruments executed over the last ten years
(i.e., from September 23, 2005 to date) retaining

(a) the firm of Giarmarco, Mullins & Horton, P.C., and any and all of its
antecedent firms, as legal counsel for the City of Hamtramck in any respect;

(b) to the extent not completely contained within the documents produced
by the City in response to request (i)(a), the same for attorney John C. Clark; and

(c) to the extent not completely contained within the documents produced
by the City in response to request (i)(a), the same for attorney J. Travis Mihelick.

Request # (ii) All documents, 1 including but not limited to, billing statements, any
written correspondence, notes respecting phone correspondence relative thereto, in the
Citys possession and those available to it, relating in any way to

(a) billing for and payment of any and all legal services rendered by the
firm and attorneys identified in Request (i)(a), (b) and (c), together and separately, in
respect of the case of

1
Document as used in requests (ii)(a)(b) and (c) shall have its customary broad
meaning and shall include, without limitation, the following items, whether original or
copies: correspondences, emails, records, schedules, tables, charts, reports, memoranda,
notes, including marginal notes on documents, calendars, diaries, letters, telegrams,
invoices, orders, order forms, messages, (including reports or telephone conversations or
conferences), minutes, interoffice communications, photographs, audio and video
recordings, all electronically stored information, including without limitation, that
contained in a computer database capable of production in written format and all other
written or printed material of any kind and all information preserved in permanent form.
P.O. Box 12422 * Hamtramck, MI 48212 * 313-455-8882 * tranbeverly@gmail.com
 Steve Shaya v. City of Hamtramck, et al.
US District Court
Eastern District of MI, Southern Division
Case No. 14-cv-11112

(b) billing for and payment of any and all legal services rendered by the
firm and attorneys identified in Request (i)(a), (b) and (c), together and separately, in
respect of the case of

Shaya v. Cathy Square and City of Hamtramck

State of Michigan
Wayne County Circuit Court
Case No. 14-013728-NZ

(c) billing for and payment of any and all legal services rendered by the
firm and attorneys identified in Request (i)(a), (b) and (c), together and separately, in
respect of the case of

The Matter of the Claim of Steve Shaya

State of Michigan
MI Administrative Hearing System
Appeal No. 14-030920-UA
Case No. 3289629
Administrative Law Judge Hearing on Shayas Appeal from a UIA
Redetermination holding him disqualified from Unemployment
Compensation benefits
ALJ: Karen M. Carpenter

(d) billing for and payment of any and all legal services rendered by the
firm and attorneys identified in Request (i)(a), (b) and (c), together and separately, in
respect of the case of

State of Michigan
MI Department of Labor and Economic Growth
Division of Unemployment Appeals
On Appeal to Michigan Compensation Appellate Commission
Appeal No. 14-030920-UA
Case No. 3289629
Hamtramcks Appeal to MCAC from ALJs Decision

Request # (iii) Identification of any and all codes and other indicia on the referenced
billing documents for services rendered, as described above, required to differentiate
the billings for the cases identified in Requests (ii)(a), (b), (c) and (d) from billings from
other matters contained in each of the documents produced under Request (ii).

P.O. Box 12422 * Hamtramck, MI 48212 2 313-455-8882 * tranbeverly@gmail.com

Request # (iv) Copies of all billing statements and associated documents for legal
services performed by (a) any other law firm than Giarmarco, Mullins & Horton, P.C.,
and (b) any other attorney than John C. Clark and J. Travis Mihelick in each of the cases
set forth in Request (ii)(a), (b), (c) and (d).

If you have other information or instructions on how to parse out the

firm/lawyers billings with regard to the cited cases, to permit a complete and accurate
accounting of all billings in subject cases, that information would be greatly appreciated
and is likewise requested under the indicated FOIA requests.

Thank you for your prompt attention and courtesies in these regards.

Sincerely,

/s/Beverly Tran

cc: Margaret Scanio

Director of Human Resources
City of Hamtramck
City Hall, 3rd Floor
3401 Evaline
Hamtramck, MI 48212

P.O. Box 12422 * Hamtramck, MI 48212 3 313-455-8882 * tranbeverly@gmail.com