Free Motion to Compel - District Court of Colorado - Colorado

Case 1:03-cv-01973-PSF-MJW

Document 208-3

Filed 05/16/2006

Page 1 of 3

HJ

Case 1:03-cv-01973-PSF-MJW

Document 208-3

Filed 05/16/2006

Page 2Page 1 of2 of 3

Gottlieb, Richard
From: Sent: To: Michael R. McCurdy [mmccurdy~fwlaw.com] Monday, April 10, 2006 11:40 AM Gottlieb, Richard

Subject: RE: Rule 69 Discovery That was my plan, but I was out sick for about 3-days. I'll get to it ASAP as I deal with similar emails from others on other cases. Seems like the assembly line kept running while I was gone. Hope all is well. Mike

From: Gottlieb, Richard [mailto: [email protected]] Sent: Monday, April 10, 2006 6:39 AM To: Michael R. McCurdy; Tamara Hoffbuhr Cc: Joshua Maximon (E-mail); Greer, Laura
Subject: RE: Rule 69 Discovery I was expecting something last week. Can you update me on where you stand? Thanks. Original Message

From: Michael R. McCurdy [mailto:mmccurdy©fwlaw.com] Sent: Thursday, March 30, 2006 1:23 PM To: Gottlieb, Richard; Tamara Hoffbuhr Cc: Joshua Maximon (E-mail); Greer, Laura Subject: RE: Rule 69 Discovery
Richard, I've been buried lately. My apologies for the delayed response. I do intend to supplement/clarify our discovery responses to some extent, but likely will not get to it until next week. Mike

From: Gottlieb, Richard [mailto:RGottlieb©KilpatrickStockton.com] Sent: Monday, March 20, 2006 2:55 PM To: Michael R. McCurdy; Tamara Hoffbuhr Cc: Joshua Maximon (E-mail); Greer, Laura Subject: FW: Rule 69 Discovery
Mike and Tamara
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We have not heard back from you on our request that Mr. Knutson supplement his responses to Walker's

5/3/2006

Case 1:03-cv-01973-PSF-MJW

Document 208-3

Filed 05/16/2006

Page 3 Page 2 of 2 of 3

Rule 69 discovery. Please let me know if you plan to respond so that we can follow up accordingly. Thank you, Richard Original Message From: Gottlieb, Richard Sent: Monday, February 13, 2006 10:31 AM To: Michael R. McCurdy Esq. (E-mail); Tamara A. Hoffbuhr (E-mail) Cc: Greer, Laura; Joshua Maximon (E-mail) Subject: Rule 69 Discovery Mike and Tamara
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Please see the attached regarding Mr. Knutson's recent discovery responses and our request that they be supplemented. Richard

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KILPATRICK STOCKTON LLP
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Richard S. Gottlieb
Kilpatrick Stockton LLP 1001 West Fourth Street Winston-Salem, NC 27101-2400 336 607 7484 f336 734 2643
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5/3/2006