Defendant’s Motion for Reconsideration

The Court heard and denied the University of Michigan’s initial Motion for Summary Disposition. On May 17, 2006, Defendant filed a motion asking the Court to reconsider its earlier decision.

In reviewing a motion for Summary Disposition, the Court must view all of the evidence in a light most favorable to the non moving party (in this case the Plaintiff). A Court should grant Summary Disposition only if there are no genuine issues of material fact and the Defendant is entitled to judgment as a matter of law.

Below are links to the Defendant’s Brief in Support of its Motion for Reconsideration. There are also links to all of the Exhibits, Affidavits and Deposition Testimony that are cited in and attached to the Brief.

Defendant’s Brief Support of Motion for Reconsideration

Defendant’s Exhibit A — February 10, 1995 Lehman Offer Letter to Hammer
Defendant’s Exhibit B — UM Faculty Handbook
Defendant’s Exhibit C — UMLS Tenure Standards and Procedures
Defendant’s Exhibit D — February 28, 2000 Lehman Letter to Hammer
Defendant’s Exhibit E — July 21, 2000 Hammer e-mail to Lehman
Defendant’s Exhibit F — August 14, 2000 Lehman e-mail to Hammer
Defendant’s Exhibit H — October 19, 2001 Hammer e-mail to Howse
Defendant’s Exhibit I — January 2002 Report of Tenure Committee
Defendant’s Exhibit J — January 2, 2003 Hammer e-mail to Clousus
Defendant’s Exhibit K — December 29, 2002 Hammer e-mail to Mahoney
Defendant’s Exhibit L — January 17, 2003 Hammer Letter to Colleagues
Defendant’s Exhibit M — February 25, 2003 Mahoney Letter to Hammer
Defendant’s Exhibit N — November 25, 2002 Hammer Memo to Grievance Review Board
Defendant’s Exhibit O — SPG 201.88 Notice of Non-Reappointment
Defendant’s Exhibit P — SPG 201.13 Acquiring Protection of Regent’s By-laws 5.09
Defendant’s Exhibit Q — September 5, 2002 Lehman Letter to Hammer

Defendant-Ben-Shahar Deposition
Defendant-Brodie Affidavit
Defendant-Caminker Deposition
Defendant-Clark Deposition
Defendant-Courant Deposition
Defendant-Croley Deposition
Defendant-Friedman Deposition
Defendant-Frier Deposition
Defendant-Frumkin Deposition
Defendant-Green Deposition
Defendant-Hathaway Deposition
Defendant-Hammer Deposition
Defendant-Herzog Deposition
Defendant-Howse Deposition
Defendant-Kauper Deposition
Defendant-Lehman Deposition
Defendant-Miller (William) Deposition
Defendant-Payton Deposition
Defendant-Reimann Deposition
Defendant-Schacter Affidavit

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