Exhibit 1 — Counsel Email Exchange (Dkt. 22-2) — Norris v. Stanley (W.D. Mich.)

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EXHIBIT 1 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22-2,  PageID.750   Filed 09/21/21   Page 1 of 4

From: Ricchiuto, Anne K. <anne.ricchiuto@faegredrinker.com>  
Sent: Friday, September 17, 2021 12:28 PM 
To: Harriet Hageman <harriet.hageman@ncla.legal>; Jenin Younes <jenin.younes@ncla.legal> 
Cc: Gutwein, Stephanie L. <stephanie.gutwein@faegredrinker.com> 
Subject: RE: Surreply & Answer extension 
 
Harriet, 
 
We anticipate filing our sur-reply just as soon as we can. 
 
With respect to witnesses: if we call a witness to testify, it will be Dr. Zervos. We have not yet decided 
whether we will call him to testify. 
 
From: Harriet Hageman <harriet.hageman@ncla.legal>  
Sent: Thursday, September 16, 2021 11:59 AM 
To: Ricchiuto, Anne K. <anne.ricchiuto@faegredrinker.com>; Jenin Younes <jenin.younes@ncla.legal> 
Cc: Gutwein, Stephanie L. <stephanie.gutwein@faegredrinker.com> 
Subject: RE: Surreply & Answer extension 
 
This Message originated outside your organization. 
 
 
Anne: 
 
Thank you for the email.  We will not oppose either motion, but would greatly appreciate it if your sur-
reply could be filed no later than tomorrow so that we will have the weekend to review it.   
 
As for the witness, we will be calling Hooman Noorchashm, MD, PhD. 
 
Are you planning to call any witnesses? 
 
 
 
 
 
 
Harriet M. Hageman 
Senior Litigation Counsel 
New Civil Liberties Alliance 
1225 19th Street NW, Suite 450 
Washington, DC 20036 
Telephone:     (202) 869-5210  
Direct Dial:    (202) 908-6201 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22-2,  PageID.751   Filed 09/21/21   Page 2 of 4

Cell Number:  (307) 631-3476 
Harriet.Hageman@ncla.legal  
NOTICE:  Admitted only in Wyoming, Colorado and Nebraska.  Practice limited to matters 
and proceedings before United States Courts and agencies.  Practicing under members of 
the District of Columbia Bar. 
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NOTICE:  This e-mail is from the New Civil Liberties Alliance law firm  and is intended solely for the use of the person(s) to whom it is 
addressed.  If you believe you received this e-mail in error, please notify the sender immediately, delete the e-mail from your computer and do 
not copy or disclose it to anyone else.  If you are not an existing client of the New Civil Liberties Alliance, do not construe anything in this e-mail 
to make you a client unless it contains a specific statement to that effect and do not disclose anything to the New Civil Liberties Alliance in reply 
that you expect or want it to hold in confidence.  If you properly received this e-mail as a client, co-counsel or retained expert of the New Civil 
Liberties Alliance you should maintain its contents in confidence in order to preserve the attorney-client or work product privilege that may be 
available to protect confidentiality. The sender of this email is an attorney. 
 
From: Ricchiuto, Anne K. <anne.ricchiuto@faegredrinker.com>  
Sent: Thursday, September 16, 2021 8:38 AM 
To: Harriet Hageman <harriet.hageman@ncla.legal>; Jenin Younes <jenin.younes@ncla.legal> 
Cc: Gutwein, Stephanie L. <stephanie.gutwein@faegredrinker.com> 
Subject: Surreply & Answer extension 
 
Harriet and Jenin, 
 
I am writing with two requests for you to consider and two questions: 
 
1. We intend to file a motion for leave to surreply to your new argument that MSU lacks authority 
to require vaccinations. May we show this motion for leave as unopposed? 
2. Our deadline to respond to the Complaint is the day after the hearing, September 23. Will you 
consent to an extension of time until October 14 for our response? 
 
It is my assumption that you have decided not to file a motion to continue the hearing; is that correct? 
Finally, can you please let me know which, if any, witnesses you intend to call at the hearing next week? 
 
Thanks very much. 
Anne 
 
Anne K. Ricchiuto 
Partner 
anne.ricchiuto@faegredrinker.com 
Connect: vCard 
+1 317 237 1420 direct / +1 317 237 1000 fax 
Faegre Drinker Biddle & Reath LLP 
300 N. Meridian Street, Suite 2500 
Indianapolis, Indiana 46204, USA 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22-2,  PageID.752   Filed 09/21/21   Page 3 of 4

 
***************************** 
This message and any attachments are for the sole use of the intended recipient(s) and may contain 
confidential and/or privileged information. Any unauthorized review, use, disclosure or distribution is 
prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy 
all copies of the original message and any attachments. Thank you. 
***************************** 
***************************** 
This message and any attachments are for the sole use of the intended recipient(s) and may contain 
confidential and/or privileged information. Any unauthorized review, use, disclosure or distribution is 
prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy 
all copies of the original message and any attachments. Thank you. 
***************************** 
 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22-2,  PageID.753   Filed 09/21/21   Page 4 of 4

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