Indeed, several courts have found that the Michigan Supreme Court's decision in Saurman abrogated Bakri. See e.g., Bowden v.American Home Loan Mtg. Servicing, Inc., 2012 WL 628543 (E.D. Mich., Feb. 27, 2012) (Cook, Jr. J.); Smith v. Litton Loan Servicing, LP, 2012 WL 6542060 (E.D. Mich., Feb. 28, 2012) (Duggan, J.) ; see also Duff v. Federal Nat. Mtg. Ass'n, 2012 WL 692120 at *4 (E.D. Mich., Feb. 29, 2012). CONCLUSION