Free Reply to Response to Motion - District Court of Colorado - Colorado

Case 1:03-cv-02462-WYD-PAC

Document 73

Filed 12/13/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-02462 WYD-PAC

BOBBY L. PADILLA Plaintiff, v SAN LUIS CENTRAL RAILROAD COMPANY, Defendant.

PLAINTIFF'S REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO HAVE OBJECTION/COMMENT OF THE DEFENDANT RULED UPON IN TERMS OF THE PRESERVATION DEPOSITION OF DAVID WONG, MD For the above, plaintiff, by his attorney John A. "Jack" Kintzele, respectfully states: Plaintiff is seeking a ruling upon the admissibility of the of the exhibit identified during the deposition, the Curriculum Vitae of David Wong, MD, since the defendant stated no objection to the Curriculum Vitae, Exhibit One (1) of the deposition. Please see Baicker-McKee, et al, Federal Civil Rules Handbook at 668 (2006) attached.

Case 1:03-cv-02462-WYD-PAC

Document 73

Filed 12/13/2005

Page 2 of 2

Respectfully Submitted, s/John A. "Jack" Kintzele_____ John A. "Jack" Kintzele, #1842 Attorney for Plaintiff 1317 Delaware Street Denver, Colorado 80204 Telephone: 303-892-6494 FAX: 303-893-2053 E-mail: [email protected] Attorney for Plaintiff Certificate of Mailing On this the 13th day of December 2005 a copy of the above was mailed, postage prepaid to: Bobby Padilla P.O. Box 2817 Espanola, NM 87532 On this the 13th day of December 2005 a copy of the above was electronically filed to: Evan S. Lipstein, Esq. 12600 West Colfax Avenue, #C-400 Lakewood, CO 80215 s/John A. "Jack" Kintzele_____ John A. "Jack" Kintzele, #1842

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