Free Motion to Compel - District Court of Colorado - Colorado

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

Document 355-13

Filed 02/23/2006

Page 1 of 3

EXHIBIT L

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

(

Document 355-13

Filed 02/23/2006

Page 2 of 3 Page lof2

Lowry, Cassie

From: Carr, David J.
Sent: Monday, October 10, 2005 10:28 AM

To: Lowry, Cassie
Subject: FW: Heartland I - Outstanding Personnel Files (840)
Correspondence file.--DJC

-----Original Message----From: Carr, David J.
Sent: Monday, October 10, 2005 10:24 AM

To: 'Fisher, Michele'; Pockrass, Steven F.
Cc: Claeys, Peggy.; Johnson, Amy; Hauboldt, Courtney; Lukas, Paul
Subject: RE: Heartland I - Outstanding Personnel Files (840)

Michele--It was my understanding from speaking with Paul, that we were starting with the personnel files for LO

deponents, and focusing on them first. We could just as easily ask you where the production responses and
interrogatory answers are for the other 850 plus plaintiffs. Do you really want paper production of all plaintiff personnel files? Please discuss with Paul, and we will go from there. I will check on the DEF 5414-5436 issue. Thanks, DJC

-----Original Message---~From: Fisher, Michele (mailto:fisher(§nka.com) Sent: Friday, October 07,20055:20 PM To: Carr, David J.; Pockrass, Steven F. Cc: Claeys, Peggy.; Johnson, Amy; Hauboldt, Courtney; Lukas, Paul
Subject: Heartland I - Outstanding Personnel Files (840)

CD Name: NK001

Delivery Format: Summation
Delivery Date: October 5, 2005

After reviewing Defendant's documents recently produced, we noticed we are stil missing personnel files for the attached. In addition, documents bates stamped DEF 05414-DEF 05436 are missing. Please advise as to when we can expect production of these documents. Thank you.
-:-:10.07.05 Missing Personnel Files (840).xls::::

Michele R. Fisher
Nichols Kaster & Anderson, PLLP
4600 IDS Center
80 South 8th Street

10/1 0/2005

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

(

Document 355-13

Filed 02/23/2006

Page 3 of of2 Page 2 3

Minneapolis, MN 55402
Direct Dial: (612) 256-3229

Facsimile: (612) 338-4878

Website: ww.nka.com and ww.overtimecases.com

The information contained in this transmission is attorney privileged and/ or confidential information intended for the

use of the individual or entity named above. If the reader of this message is not the intended, you are heref? notifed that
a1' dissemination distribution or copying of this communication is strictlY prohibited.

10/1 0/2005