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No Total Exhaustion Rule for Michigan District Court
The author of the opinion in Jenkins v. Toombs adheres to his "no total
exhaustion" position, with some acerbity, in a case wherein the magistrate
judge adopted the "yes total exhaustion" position of a different judge in
the same district who had more recently adopted total exhaustion in
Smeltzer v. ...
exhaustion" position, with some acerbity, in a case wherein the magistrate
judge adopted the "yes total exhaustion" position of a different judge in
the same district who had more recently adopted total exhaustion in
Smeltzer v. ...
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