Free Motion to Expedite - District Court of Colorado - Colorado

Case 1:04-cv-00779-PSF-BNB

Document 79-3

Filed 09/09/2005

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EXHIBIT "B"

Case 1:04-cv-00779-PSF-BNB

Document 79-3

Filed 09/09/2005

Page 2 of 4

From: Sent:

To:
cc:

Subject:
Dear Counsel-

Don Lawrence [[email protected]] Tuesday, September 06,2005 3:23 PM Wilson, Diane Westwood [email protected]; [email protected]; [email protected]; abensonabhf1aw.com; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; GEOFFREY RACE Re: Denver Fuel Fire Litigation - Component Inspection

Neither Sept. 14 nor Sept. 15 is workable for our expert. Accordingly, BA will not oppose a 30 day extension for designation of principal experts (to Oct. 151, a 30 day extension for defense experts (to Nov. 141, and an extension for edesignating rebuttal experts to Dec. 19 (the Monday following the court Settlement conference). Don Lawrence

- - - - Original message - - - >Date: Fri, 2 Sep 2005 18:54:12 -0400 >From: "Wilson, Diane Westwood" >Subject: Re: Denver Fuel Fire Litigation - Component Inspection >To: [email protected]>, , [email protected]>, [email protected]>, cbkahnabhf- law.com>, , , >Cc: [email protected]>, , , [email protected]>
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I will let our expert know that the 8th is cancelled. I will not know until Tuesday whether the 14th or 15th will work. As soon as I know, I will let: you know. Thanks, Diane Diane Westwood Wilson Condon & Forsyth LLP Times Square Tower 7 Times Square New York, New York 10036 Tel: 212.694.6780 FG: 212.894.6781 PLEASE TREAT THIS MESSAGE AS PRIVILEGED AND CONFIDENTIAL

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- - - - - Original Message----From: Dane JAQUES To: [email protected] cmmcquillen9amm-law.com>; [email protected] ; abenson4bhf-1aw.com eabensonabhf-law.com>; bkahnabhf-1aw.com ; Wilson, Diane Westwood ; Mark Dombroff ; [email protected] ; [email protected]


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CC: CHARLES Ryan ; [email protected] ; [email protected] ; [email protected] Senti Fri Sep 02 15:23:26 2005 Subject: RE: Denver Fuel Fire Litigation - Component Inspection
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Case 1:04-cv-00779-PSF-BNB
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Document 79-3

Filed 09/09/2005

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I just heard back from Richard McSwain. He has a trial set to start in Canada on Tuesday and expects to be in attendance from Tuesday through Friday (9-8). He is able to free up Wednesday September 14th, continuing to Thursday morning, September 15th for the inspection. That would allow sufficient time to have his report by September 30th (and would shift all other experts reports by 15 days.) Please let me know whether this works for your experts. Dane B. Jaques, Esq. Dombroff & Gilmore, PC 1676 International Drive, Penthouse McLean, VA 22102 Off ice : 703-336-8709 Cell Phone: 703-966-6111 703-336-8750 Facsimile: Email : [email protected] PRIVILEGED & CONFIDENTIAL This communication is subject to the Attorney-Client and Attorney Work Product Privileges.
> > > "Wilson, Diane Westwood" 09/01/05 02:12PM >>> Counsel : The position of plaintiff British Airways is reflected in the attached letter. Regards , Diane Westwood Wilson Condon & Forsyth LLP Times Square Tower 7 Times Square New York, New York I0036 Tel: 212.894.6780 Fax: 212.894.6781

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PRIVILEGE AND CONFIDENTIALITY NOTICE: This message is intended only for use by the named addressee and may contain privileged and/or confidential information. If you are not the named addressee you should not disseminate, copy or take any action in reliance on it. If you have received this message in error please notify [email protected] and delete this message and any attachments accompanying it immediately. Thank you.

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- - - - - Original Message----From: Dane JAQUES [mailto:[email protected] Sent: Wednesday, August 31, 2005 3:33 PM TO: [email protected]; [email protected]; abenson9bhf-1aw.com; bkahnabhf-1aw.com; Wilson, Diane Westwood; [email protected];
[email protected] Cc: CHARLES Ryan; Mark Dombroff Subject: Denver Fuel Fire Litigation
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[email protected]; [email protected];

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Case 1:04-cv-00779-PSF-BNB
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Document 79-3

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Further to D.C.COLO.LCivR 7.1 - MOTIONS, please let me know by close of business tomorrow whether you agree to produce the components requested in the attached letter and do not object to the additional time requested for AS11 to s e n e its expert reports. We would agree to shift all of the expert report due dates by the same amount of time. Dane B. Jaques, Esq. Dombroff & Gilmore, PC 1676 International Drive, .Penthouse McLean, VA 22102 Off ice : 703-336-8709 Cell Phone: 703-966-6111 703-336-8750 Facsimile: djaquesadgli tigators com Email : PRIVILEGED & CONFIDENTIAL This communication is subject to the Attorney-Client and Attorney Work Product Privileges.

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Don Lawrence Donald Lawrence Jr., P.C. 26 West D r y Creek Circle Suite 460 Littleton, CO 80120
72 0 - 2 83 -4414 (Phone1 720-283-2200 (Fax)

NOTICE The information contained in this message is confidential and protected by the attorneyclient privilege and by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510 et seq. It is intended only for the addressee and use or disclosure by any other person is prohibited. If you have received this email in error, please permanently delete it and notify the sender immediately at 720-283-4414. Thank you. Although this e-mail and any attachments are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Donald Lawrence, Jr., P.C., for any loss or damage arising in any way from its use.

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