DETROIT - The Michigan Council 25 of the American Federation of State, County and Municipal Employees (AFSCME), which represents employees of the bankrupt City of Detroit, on Nov. 13 filed a brief in the U.S. Bankruptcy Court for the Eastern District of Michigan contending that the city failed to satisfy its duty to negotiate in good faith with the union prior to filing for bankruptcy (In Re: City of Detroit, No. 13-53846, Chapter 9, E.D. Mich. Bkcy.).