Free Objections - District Court of Colorado - Colorado

Case 1:04-cv-01160-LTB-CBS

Document 101

Filed 05/30/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01160 ­LTB-CBS ISABELLE DERKEVORKIAN, Plaintiff, vs. LIONBRIDGE TECHNOLOGIES, INC., d/b/a LIONBRIDGE US, INC., SHARRYN E. ROSS and ROSS, MARTEL & SILVERMAN, LLP, Defendants. ______________________________________________________________________________ PLAINTIFF'S OBJECTIONS TO DEFENDANT'S TRIAL EXHIBITS ______________________________________________________________________________ Plaintiff, by her attorneys, Dietze and Davis, P.C., respectfully submits her objections to Defendant's Trial Exhibits, which were provided to Plaintiff on May 16, 2006. Exhibit A B C E F I O Description Plaintiff's responses to Interrogatories from Defendants Defendant's Employee Handbook - 2001 Defendant's Employee Handbook - 2002 Permanent Resident Program - 2001 Permanent Resident Program - 20021 Plaintiff's Performance Evaluation 11/05/01 (Deposition Exhibit 17) Tymkovich Notes dated 9/27/02 (Deposition Exhibit 32) Basis for Objection FRE 402 - Relevance FRE 402 ­ Relevance FRE 802 - Hearsay FRE 402 ­ Relevance FRE 802 - Hearsay FRE 402 ­ Relevance FRE 802 - Hearsay FRE 402 ­ Relevance FRE 802 - Hearsay FRE 802 - Hearsay FRE 802 - Hearsay

Case 1:04-cv-01160-LTB-CBS

Document 101

Filed 05/30/2006

Page 2 of 4

P Q S U V

Tymkovich Notes dated 9/30/02 (Deposition Exhibit 33) Peralta email dated 9/30/02 (Deposition Exhibit 35) Employee List (Deposition Exhibit 39)

FRE 802 - Hearsay FRE 403 Cumulative2 FRE 802 ­ Hearsay FRE 402 - Relevance FRE 402 - Relevance FRE 802 ­ Hearsay FRE 403 Cumulative3 FRE 802 ­ Hearsay FRE 403 Cumulative4 FRE 802 ­ Hearsay FRE 402 ­ Relevance FRE 901 Authenticity FRE 802 ­ Hearsay FRE 403 Cumulative5 FRE 802 ­ Hearsay6 Plaintiff has not been provided with this exhibit and therefore will reserve her right to object Plaintiff has not been provided with this exhibit and therefore will reserve her right to object

Entry of Appearance by Ross (Deposition Exhibit 52) Ross email dated 10/15/02 (Deposition Exhibit 54)

W

Forward of 10/15/02 Ross email to Plaintiff dated 10/17/02 and attached email string Peralta email to Tymkovitch dated 6/15/02

X

Y Z A1 A3

Tymkovich notes dated 9/19/02 Peralta email to Plaintiff dated 9/30/02 December 5 (sic), 2003 letter from Plaintiff's counsel to Ms. Shukur and enclosures Summary and/or Demonstrative Exhibit of Events Timeline

A4

Summary and/or Demonstrative Exhibit of Plaintiff's employment

Respectfully submitted,

Case 1:04-cv-01160-LTB-CBS

Document 101

Filed 05/30/2006

Page 3 of 4

DIETZE and DAVIS, P.C. By: "s/ Joel C. Maguire" Joel C. Maguire Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected] Attorney for Plaintiff Isabelle DerKervorkian
1

Plaintiff has listed a version of the Permanent Resident Program (See Plaintiff's Exhibit 1). This is the version that is Deposition Exhibit 2. Defendant's Exhibit F contains significant additional information that Plaintiff believes is not relevant to this case. Also, the portion of Exhibit F relating to the Permanent Resident Program appears to be in a different format. If the language is the same as found in Deposition Exhibit 2, however, Plaintiff will not object to the portion of Exhibit F relating to the Permanent Resident Program. Defendant's Exhibit Q is part of the email string contained in Defendant's Exhibit R. Defendant's Exhibits V and W are the same except that W shows forwarding to Plaintiff. Defendant's Exhibits V and W are the same except that W shows forwarding to Plaintiff.

2 3 4 5

Defendant's Exhibit Z is the same as Defendant's Exhibit Q and also is part of the email string contained in Defendant's Exhibit R. Defendant's Exhibit A1 consists of letters and emails exchanged between Plaintiff's counsel and Lionbridge and its general counsel. Although Plaintiff's counsel stands by the statements made in his letters and emails, the statements of both counsel are entirely hearsay, since they are based on information provided by others or gathered from documents.

6

CERTIFICATE OF SERVICE

Case 1:04-cv-01160-LTB-CBS

Document 101

Filed 05/30/2006

Page 4 of 4

I hereby certify that on May 30, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Dan S. Cross [email protected] [email protected] By: "s/ Susan J. Armour" Susan J. Armour, Legal Assistant Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected]