Plaintiff’s Opposition to Defendant’s Motion for Reconsideration

On June 20, 2006, Plaintiff Filed its Brief in Opposition to Defendant’s Motion for Reconsideration of the Denial of its Motion for Summary Disposition.

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 Plaintiff’s Brief. There are also links to all of the Exhibits, Affidavits and Deposition Testimony that are cited in and attached to the Brief.

Plaintiff’s Brief in Opposition to Defendant’s Motion

Plaintiff-Hammer Affidavit
Plaintiff-Hammer Affidavit Exhibit 1
Plaintiff-Hammer Curriculum Vitae

Plaintiff’s Exhibit 1 — March 27, 1995 Syverud letter to Hammer
Plaintiff’s Exhibit 2 — Undated Friedman e-mail to Colker
Plaintiff’s Exhibit 3 — February 28, 2000 Lehman letter to Hammer
Plaintiff’s Exhibit 4 — August 14, 2000 Lehman e-mail to Hammer
Plaintiff’s Exhibit 5 — 2002 Majority Tenure Committee Report
Plaintiff’s Exhibit 6 — 2002 White Dissenting View on Tenure Committee Report
Plaintiff’s Exhibit 7 — 2002 Malamud Concurring View on Tenure Committee Report
Plaintiff’s Exhibit 8 — Minutes of Faculty Tenure Meetings
Plaintiff’s Exhibit 9 — February 27, 2002 Caminker e-mail to Malamud
Plaintiff’s Exhibit 10 — June 4, 2002 Caminker e-mail to Lehman
Plaintiff’s Exhibit 11 — April 4, 2002 Hammer letter to Courant
Plaintiff’s Exhibit 12 — November 16, 2002 Lehman e-mail to Hammer
Plaintiff’s Exhibit 13 — October 22, 2002 Hammer e-mail to Lehman
Plaintiff’s Exhibit 14 — December 15, 2002 Caminker e-mail to Lehman
Plaintiff’s Exhibit 15 — February 26, 2002 Lehman e-mail to General Council Liz Barry
Plaintiff’s Exhibit 16 — UM Regent’s By-Laws: Chapter V Faculties and Academic Staff
Plaintiff’s Exhibit 17 — J.J. White, “Tribute to James A. Martin
Plaintiff’s Exhibit 18 — January 30, 2002 Tenure Review of Einer Elhauge
Plaintiff’s Exhibit 19 — Undated Friedman e-mail to Colker
Plaintiff’s Exhibit 20 — February 15, 1996 Logue e-mail to Hammer
Plaintiff’s Exhibit 21 — The Future of Family Law
Plaintiff’s Exhibit 22 — Carl E. Schneider: Work on Family Law
Plaintiff’s Exhibit 23 — Thomas Kauper’s Reviews of Hammer’s Writing
Plaintiff’s Exhibit 24 — November 22, 2002 Lehman e-mail to Hammer
Plaintiff’s Exhibit 25 — Sherman Clark, “The Character of Persuasion,” Ave Maria L. Rev.
Plaintiff’s Exhibit 26 — July 2003 Report to Board of Regents on Faculty Resignations
Plaintiff’s Exhibit 27 — January 14, 2003 Green letter to Krislov
Plaintiff’s Exhibit 28 — November 18, 1997 Whitman Memo to Hammer
Plaintiff’s Exhibit 29 — April 23, 2004 Report of Task Force on GLBT Campus Climate
Plaintiff’s Exhibit 30 — January 29, 2002 Green e-mail to Howse
Plaintiff’s Exhibit 31 — Chronology of Events and Attached Correspondence (146 pages)
Plaintiff’s Exhibit 32 — April 24, 2002 Whitman e-mail to Westin
Plaintiff’s Exhibit 33 — April 20, 2005 Guideline Regarding Time to Tenure Review

Plaintiff-Appendix On Credibility
Plaintiff-Caminker Deposition
Plaintiff-Clark Deposition
Plaintiff-Courant Deposition
Plaintiff-Friedman Deposition
Plaintiff-Frumkin Deposition
Plaintiff-Herzog Deposition
Plaintiff-Huron Hills Baptist Church Website
Plaintiff-Lehman Deposition
Plaintiff-Logue Deposition
Plaintiff-Miller (Frances) Affidavit
Plaintiff-Miller (William) Deposition
Plaintiff-Schneider Deposition
Plaintiff-Transcript Private Investigation
Plaintiff-Veenstra Decision

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