Free Objections - District Court of Colorado - Colorado

Case 1:04-cv-01062-ZLW-BNB

Document 118

Filed 10/21/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01062-ZLW-BNB THE QUIZNO'S MASTER LLC and THE QUIZNO'S FRANCHISE COMPANY LLC, Plaintiffs, v. R&B MANAGEMENT GROUP, LLC, an Alabama limited liability company, ROYCE GWIN, an individual, and REBECCA GWIN, an individual Defendants. QUIZNO'S OBJECTIONS TO DEFENDANTS' EXHIBITS Plaintiffs The Quizno's Master LLC and The Quizno's Franchise Company LLC (hereinafter referred to singularly as "Quizno's") hereby submits its Objections to Defendants' Exhibits as follows. Quizno's reserves the right to object to any exhibit on the grounds of relevancy and odes not waive a relevancy objection to any exhibit by noting a relevancy objection below. Certain documents from Defendants' files contain confidential and proprietary information, those documents, which are noted below, should be treated as confidential together with any documents noted as confidential on Defendants' exhibit list. Exhibit No. B E F G OBJECTION Hearsay, foundation Foundation, authenticity, best evidence, confidential Relevance, foundation, authenticity Foundation, authenticity, best evidence, confidential

DE052930.002

Case 1:04-cv-01062-ZLW-BNB

Document 118

Filed 10/21/2005

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Exhibit No. H I J K L M N O P Q S U V AG AH AI AJ AM AN AO AP AQ AR AS AT AU AV AW AX AY AZ BA BB BC BD BE BF BG BH BI

OBJECTION Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, confidential Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation Foundation, authenticity, confidential Foundation, authenticity Foundation, authenticity, relevance Authenticity Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Foundation, authenticity, best evidence, Hearsay, subject to Daubert motion Hearsay, subject to Daubert motion Hearsay, subject to Daubert motion Hearsay, subject to Daubert motion Hearsay, subject to Daubert motion Hearsay, subject to Daubert motion Relevance Relevance Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Foundation, authenticity, best evidence, Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay

confidential confidential confidential confidential confidential confidential confidential confidential

confidential confidential confidential

confidential

Case 1:04-cv-01062-ZLW-BNB

Document 118

Filed 10/21/2005

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Exhibit No. BJ BK BL BM BN BO BP BQ BR BS BT

OBJECTION Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Relevance, hearsay Foundation, relevancy, authenticity, best evidence Foundation, relevancy, authenticity, best evidence Foundation, relevancy, authenticity, best evidence Relevance, hearsay Relevance, hearsay, foundation Relevance, hearsay, foundation Respectfully submitted, /s/ Leonard H. MacPhee_________________ Leonard H. MacPhee Attorney for Plaintiffs Perkins Coie LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202 Telephone: (303) 291-2300 Facsimile: (303) 291-2400 Email: [email protected] and Fredric A. Cohen DLA Piper Rudnick Gray Cary 203 North LaSalle Street, Suite 1800 Chicago, IL 60601 (312) 368-4000

Dated this 21st day of October 2005

Case 1:04-cv-01062-ZLW-BNB

Document 118

Filed 10/21/2005

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CERTIFICATE OF SERVICE I hereby certify that on October 21, 2005 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 email addresses:


Gilbert R. Egle [email protected] [email protected]\ Dennis Kaw [email protected] Eldon E. Silverman [email protected] [email protected]



and hereby certify that on October 21, 2005 I have mailed the foregoing to the following non EM/ECF participant via U.S. Mail, postage prepaid: J.E. Sawyer, Jr. Attorney at Law 203 South Edwards Street Enterprise, AL 36330

/s/ Leonard H. MacPhee Leonard H. MacPhee Attorney for Defendant Perkins Coie LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202 Telephone: (303) 291-2300 Facsimile: (303) 291-2400 Email: [email protected]