Free Amended Document - District Court of Colorado - Colorado

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

Document 107

Filed 02/24/2006

Page 1 of 6

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-2462-WYD-PAC BOBBY PADILLA, Plaintiff, v. SAN LUIS CENTRAL RAILROAD COMPANY, Defendant. ______________________________________________________________________________ DEFENDANT'S AMENDED OBJECTIONS TO PLAINTIFF'S EXHIBITS ______________________________________________________________________________ Respectfully, Defendant objects to the Plaintiff's exhibits as follows: Exhibit 1: Exhibit 2: Exhibit 3: Exhibit 4: No objection. Hearsay, lack of foundation. Hearsay, lack of foundation. Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 5: Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 6: Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice.

1

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

Document 107

Filed 02/24/2006

Page 2 of 6

Exhibit 7:

Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 8: Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 9: Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 10: Exhibit 11: Relevance. Hearsay, lack of foundation, probative value substantially outweighed by

danger of unfair prejudice. Exhibit 12: Hearsay, lack of foundation, probative value substantially outweighed by

danger of unfair prejudice. Exhibit 13: Hearsay, lack of foundation, probative value substantially outweighed by

danger of unfair prejudice. Exhibit 14: Hearsay, lack of foundation, probative value substantially outweighed by

danger of unfair prejudice. Exhibit 15: Hearsay, lack of foundation, probative value substantially outweighed by

danger of unfair prejudice. Exhibit 16: No copy of Exhibit 16 was provided. Defendant reserves the right to state

an objection upon receipt of a copy. Exhibit 17: prejudice. Relevance, probative value substantially outweighed by danger of unfair

2

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

Document 107

Filed 02/24/2006

Page 3 of 6

Exhibit 18: unfair prejudice. Exhibit 19: unfair prejudice. Exhibit 20:

Hearsay, relevance, probative value substantially outweighed by danger of

Hearsay, relevance, probative value substantially outweighed by danger of

Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 21: Exhibit 22: Exhibit 23: Exhibit 24: Hearsay. Hearsay. No objection. Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 25: Exhibit 26: Exhibit 27: Exhibit 28: Exhibit 29: Exhibit 30: Exhibit 31: Exhibit 32: Exhibit 33: Exhibit 34: Exhibit 35: Duplicate of Exhibit 23, cumulative. Hearsay, relevance, lack of foundation. Hearsay, relevance, lack of foundation. No objection. No objection. No objection. Duplicate of Exhibit 36, cumulative, relevance. Hearsay. Hearsay, relevance. Hearsay, relevance. Hearsay. 3

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

Document 107

Filed 02/24/2006

Page 4 of 6

Exhibit 36: Exhibit 37: unfair prejudice. Exhibit 38: Exhibit 39: Exhibit 40: Exhibit 41: Exhibit 42: Exhibit 43: Exhibit 44: Exhibit 45: Exhibit 46: Exhibit 47: Exhibit 48: Exhibit 49: Exhibit 50: Exhibit 51: Exhibit 52: Exhibit 53: Exhibit 54: Exhibit 55:

No objection. Relevance, hearsay, probative value substantially outweighed by danger of

Hearsay. No objection. Hearsay, relevance. No objection. No objection. No objection. Hearsay. Hearsay. Hearsay. Hearsay, relevance, lack of foundation. Hearsay, lack of foundation, incomplete. Hearsay, lack of foundation, incomplete. Hearsay, incomplete. Hearsay, lack of foundation, incomplete. Hearsay, lack of foundation. Hearsay; lack of foundation. Hearsay, relevance. Hearsay, relevance, lack of foundation.

4

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

Document 107

Filed 02/24/2006

Page 5 of 6

Exhibit 56:

Hearsay, relevance, lack of foundation, probative value substantially

outweighed by danger of unfair prejudice. Exhibit 57: Exhibit 58: prejudice. Exhibit 59: Hearsay, relevance, lack of foundation, probative value substantially Hearsay, relevance, lack of foundation. Hearsay, probative value substantially outweighed by danger of unfair

outweighed by danger of unfair prejudice.

s/ Evan S. Lipstein Evan S. Lipstein Law Offices of Evan S. Lipstein PC 12600 West Colfax Avenue, Suite C-400 Lakewood, Colorado 80215 Telephone: 303-232-5151 Fax: 303-232-5161 Email: [email protected] Attorneys for Defendant

5

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

Document 107

Filed 02/24/2006

Page 6 of 6

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on February 24th, 2006, I electronically filed the foregoing DEFENDANT'S AMENDED OBJECTIONS TO PLAINTIFF'S EXHIBITS with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Jack Kintzele, Esq. [email protected] Attorney for Plaintiff s/ Evan S. Lipstein Evan S. Lipstein Law Offices of Evan S. Lipstein PC 12600 West Colfax Avenue, Suite C-400 Lakewood, Colorado 80215 Telephone: 303-232-5151 Fax: 303-232-5161 Email: [email protected] Attorneys for Defendant

6