Free Motion to Compel - District Court of Colorado - Colorado

Case 1:03-cv-02485-MSK-PAC

Document 355-4

Filed 02/23/2006

Page 1 of 2

EXHIBIT C

Case 1:03-cv-02485-MSK-PAC Message

Document 355-4

Filed 02/23/2006

Page 2 of 2 1 Page 1 of

Lowry, Cassie

From: Carr, David J.
Sent: Friday, April 08, 20054:58 PM

To: Lowry, Cassie
Subject: FW: CMK v. HHF Class-Wide Discovery
Importance: High

please put in the pleadings binder.--DJC

-----Original Message----From: Carr, David J.
Sent: Friday, April 08, 2005 4:58 PM To: Lukas, Paul; 'Fisher, Michele'
Subject: CMK v. HHF Class-Wide Discovery

Importance: High

Paul and Michele--I know that your reply to our objections is not due until Monday, and that we don't really have an order on conditional certification for purposes of discovery, but i thought it would be useful to go ahead and serve our class wide paper discovery now, in the event the district court judge does ultimately rule in favor of conditional certification for purposes of class wide discovery. Consequently, our Interrogatories and Production Requests are attached, and are also being served via regular maiL. I would like to talk with you about both sides' potential "Phase Two" discovery at your convenience some time next week. Thanks, DJC

David J. Carr, Esq. Partner
Ice Miller
One American Square

Box 82001 Indianapolis, IN 46282

carr~icemiller.com (direct dial) 317-236-5840 (direct fax) 317-592-4810 (cell) 317-501-3571

2/21/2006