Free Response to Motion - District Court of Colorado - Colorado

Case 1:03-cv-02344-RPM

Document 37-5

Filed 02/14/2006

Page 1 of 1 Page 1 of 1

Mike Beaver
From:
Sent:

David M. Herrera [[email protected]] Monday, January 23, 2006 2:31 PM

To : Mike Beaver Subject: DeFrancesco vc. Unum

David M. Herrera
ATTORNEY & COUNSELOR LAW AT

3600 South College, Suite 204 Fort Collins, CO 80525

/-,--w 3\ January 23,2005

Mr. Michael S. Beaver, Esq. Holland & Hart LLP 8390 East Crescent Parkway, Suite 400 Greenwood Village, CO 80 111-2800
RE: DeFrancesco v UNUM, Civil Action No. 03-M-2344 (MJW)

Dear Michael:

I have been instructed to pursue the matter of payment for amounts due based upon the 60% standard in the new UNUM contract. In accordance with your request that I consult with you beforehand, it is my intention to pursue a contempt citation since your responses do not conform to the Court's Order.
I assume you oppose the motion for contempt citation. I will file the motion on Wednesday, January 25, 2006, unless I hear otherwise from you before 5:00 p.m. I will await your response.
Cordially,

David M. Herrera
Fort Collins, Colorado 970-498-9999

Fax 970-472-5365

E-Mail: [email protected]

www.david1~erreralaw.com

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