Free Objections - District Court of Colorado - Colorado

Case 1:04-cv-00687-PSF-BNB

Document 112

Filed 08/17/2006

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00687-PSF-BNB MARY JO LAIRD, Plaintiff, v. GUNNISON COUNTY, a County of the State of Colorado, acting through THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF GUNNISON, THE BOARD OF TRUSTEES FOR THE GUNNISON COUNTY PUBLIC LIBRARY, and JOHN DEVORE and PEGGY MARTIN, in their individual capacities, Defendant.

PLAINTIFF'S OBJECTIONS TO DEFENDANTS' TRIAL EXHIBITS

Plaintiff, pursuant to the Pretrial Order in this matter (Document No.107) and pursuant to Fed. R. Civ. P. 26(a)(3), objects to the following exhibits listed by Defendants:

EXHIBIT DESCRIPTION OF EXHIBIT X Y AA BB Adams County Classification Specification (GUNNISON.00203) Pikes Peak Library District ­ Branch Manager (GUNNISON.00052) Gunnison County spreadsheet of employment infor mation for Mary Jo Laird Curriculum Vitae of Patrick Renfro

REASON FOR OBJECTION Hearsay (FRE 802) and Relevancy (FRE 402) Hearsay (FRE 802) and Relevancy (FRE 402) Hearsay (FRE 802) Hearsay (FRE 802); Testimony re qualifications of expert should be presented in front of the jury (FRE 702) and Relevancy (FRE 402) Hearsay (FRE 802); Testimony re qualifications of expert should be presented in front of the jury (FRE 702) and Relevancy (FRE 402)

CC

Curriculum Vitae of Ronald Koch

Case 1:04-cv-00687-PSF-BNB

Document 112

Filed 08/17/2006

Page 2 of 2

DD

Expert report of Ronald Koch (to include tables)

The report is not admissible as it is Hearsay (FRE 802). Plaintiff cannot cross examine a report and must have the opportunity to cross examine the live testimony of the expert.

Dated this 17th day of August, 2006. KENNEDY CHILDS & FOGG, P.C.

s/ Nathan Davidovich Nathan Davidovich Dean A. McConnell Stuart A. Jay 1050 17th Street, Suite 2500 Denver, Colorado 80265 Telephone: (303) 825-2700 Facsimile: (303) 825-0434 [email protected] ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 17, 2006, I filed the foregoing PLAINTIFF'S OBJECTIONS TO DEFENDANTS' TRIAL EXHIBITS with the United States District Court for the District of Colorado via the CM/ECF System which will send notification to following individuals:

Eric M. Ziporin, Esq. Senter Goldfarb & Rice 1700 Broadway, Suite 1700 Denver, Colorado 80290

s/ Julie Rotenberg