Free Objections - District Court of Colorado - Colorado

Case 1:04-cv-01122-LTB-MJW

Document 35

Filed 07/29/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1122-LTB-MJW DEBORA K. RUDD Plaintiff, v. BURLINGTON COAT FACTORY WAREHOUSE OF COLORADO, INC., a Colorado corporation, and MICHAEL NEUMAN, individually and in his capacity as supervisor, Defendants.

PLAINTIFF'S OBJECTIONS TO EXHIBITS PURSUANT TO FED.R.CIV.P 26 (a)(3)

PLAINTIFF, by and through her undersigned counsel, and pursuant to Fed.R.Civ.P. 26(a)(3) discloses objections to exhibits identified by Defendants in the Final Pretrial Order as follows: 1. In exhibit 4 of the Final Pretrial Order, Defendants have listed broad categories of

exhibits rather then individual documents. Plaintiff reserves the right to raise any objection to exhibits offered by Defendants at trial that have not been specifically identified in the Final Pretrial Order. 2. Plaintiff objects to any documents included in Defendants' exhibits 1, 2, 5-14, and

16, that contain statements, on the grounds of heresay. (F.R.E. 802) 3. Pursuant to Fed.R.Civ.P. 26(a)(3), Plaintiff reserves the right to object to these

and any other proffered exhibits under Rules 402 and 403 of the Federal Rules of Evidence. Respectfully submitted this 29th day of July , 2005.

Case 1:04-cv-01122-LTB-MJW

Document 35

Filed 07/29/2005

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/s Kara T. Birkedahl Kara T. Birkedahl, Esq. Silvern Law Offices, P.C. 1801 Broadway, Suite 930 Denver, Colorado 80202 Telephone: 303-292-0044 FAX: 303-292-1466 E-mail: [email protected] Attorneys for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on this 29th day of July, 2005 a true and correct copy of the above and foregoing PLAINTIFF'S OBJECTIONS TO EXHIBITS PURSUANT TO FED.R.CIV.P. 26 (a)(3) was served upon:

Jan E. Montgomery, Esq. Hamilton and Faatz, P.C. 1600 Broadway, Suite 500 Denver, Colorado 80202

Debora Rudd 814 West Clark Street Livingston, Montana 59047 Via regular U.S. mail

s/ Erica Toureau

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