Free Objections - District Court of Colorado - Colorado

Case 1:04-cv-01214-PSF-OES

Document 60

Filed 09/06/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04cv01214-PSF- OES KATHLEEN M. TOWERS, Plaintiff, vs. SAFEWAY INC., Defendant.

DEFENDANT'S OBJECTIONS PURSUANT TO FED.R.CIV.P. 26 (a)(3)
Defendant Safeway, through its attorneys, Holland & Hart LLP, hereby submits its objections pursuant to Fed.R.Civ.P. 26(a)(3) to Plaintiff's exhibits as listed in the Final Pretrial Order as follows: Objections to Plaintiff's Trial Exhibits: 1. Defendant hereby makes a general objection to any exhibit for which no

witness is listed who can authenticate the exhibit. 2. 402 and 403. 3. Defendant objects to Exhibit 7 on the basis of Federal Rules of Evidence Defendant objects to Exhibit 3 on the basis of Federal Rules of Evidence

402, 403, and 901. 4. Defendant objects to Exhibit 11 on the basis of Federal Rules of Evidence

402 and 403 and on the grounds that it is self- serving.

Case 1:04-cv-01214-PSF-OES

Document 60

Filed 09/06/2005

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5.

Defendant objects to Exhibit 14 on the basis of Federal Rules of Evidence

402, 403, and 702. 6. Defendant objects to Exhibit 15 on the basis of Federal Rules of Evidence

402, 403, and 702. 7. Defendant objects to Exhibit 16 on the basis of Federal Rules of Evidence

402 and 403 and because there is no witness listed who can authenticate the documents. 8. Defendant objects to Exhibit 17 on the basis of Federal Rules of Evidence

402 and 403, 702, 901, and as misleading and self- serving. 9. 10. 11. Defendant objects to Exhibit 21 on the basis of rules 402 and 403. Defendant objects to Exhibit 24 on the basis of rules 402 and 403. Defendant objects to Exhibit 46 on the basis of rules 602, 901 and as self-

serving and misleading. 12. Defendant objects to Exhibit 47 on the basis of Federal Rules of Evidence

402 and 403, 702, 901, and as misleading and self- serving.

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Case 1:04-cv-01214-PSF-OES

Document 60

Filed 09/06/2005

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Dated: September 6, 2005

Respectfully submitted,

s/Emily Hobbs- Wright Jim Goh Emily Hobbs- Wright HOLLAND & HART LLP 555 ­ 17th Street, Suite 3200 Denver, CO 80202 (303) 295-8584 Fax No.: (303) 295-8261 [email protected] [email protected] ATTORNEYS FOR DEFENDANT SAFEWAY INC.

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Case 1:04-cv-01214-PSF-OES

Document 60

Filed 09/06/2005

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CERTIFICATE OF SERVICE

I hereby certify that on September 6, 2005, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e- mail addresses:

[email protected]

s/Emily Hobbs- Wright Emily Hobbs- Wright Holland & Hart LLP 555 ­ 17th Street, Suite 3200 P. O. Box 8749 Denver, CO 80202 (303) 295-8584 Fax No. (303) 295-8261 [email protected]

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