Free Statement - District Court of Arizona - Arizona

Meyers, Marshall
From: Meyers, Nlarshaii
Sent: Friday, January 27, 2006 1:51 PM
To: ’Shattuck, William M} ‘
Subject: RE: DeShazer ;
Both Iudge Martone’s and Iudge SiIver’s re the pto and documents attendant therewith. I am going offliudge Martone’s g
order for all directions. ifyou are available by phone it might make some of these final details easier to resolve
Marshall Meyers
Krohn & Moss, Ltd t
e-mail: [email protected]
web: www.:consumer·lawcenter: com
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT
FROM DISCLOSURE UNDER APPLICABLE LAW If the reader of this message is not the intended recipient or agent
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our address record can be corrected.: Thank you. . .
——·-- Original Message ---——
From: Shattuck, William M. [mailt0:WMS@quarlescom] Q
Sent: Friday, Ianuary 27, 2006 1:49 PM
To: Meyers, Marshall 2
Subject: RE: DeSha2er
What standing order? j
———-- Original Message ----—
From: Meyers, Marshall [mailtomimeyers@consumerlawcenter com] Q
Sent: Friday, January 27, 2006 1:37 PM
To: Shattuck, William M. f
Subject: RE: DeShazer T ----
Bill, the Iudge's standing order says to do it together in the manner I wrote below, do you refuse? g
Mar shall Meyers
Krohn & Moss, Ltd.
e-mail: mmeyer·s@consumerlawcenterpcom as
web: www consumerlawcerrterncom f
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ·
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT fir
FROM DISCLOSURE UNDER APPLICABLE LAW. Ifthe reader of this message is not the intended recipient or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination or
copying of this communication is strictly prohibited Ifyou have received this electronic transmission in error, please
delete it from your system without copying it, and notify the sender by reply e—mail or b_y caliing 602 275 5588, so that _
OUI address record can be corrected. I`hank you. E
i
Case 2:03-cv—OO869-FJIVI Document 188-2 Filed O1/27/2006 Page 1 of 4

--——— Original Message -----
From: Shattuck, William M [mailto:WMS@quarles com] I
Sent: Friday, January 27, 2006 1:34 PM
To: Meyers, Marshall
Subject: RE: DeShazer Y
That is indeed the concept of a proposed statement. We will file our proposed statement, you can of course file your
proposed statement —
----- Original Message ——-——
From: Meyers, Marshall [mailto:mrrreyers@consumerlawcenter com]
Sent: Friday, January 27, 2006 1:29 PM E
To: Shattuck, William M.; Jack Gunn
Cc: John C. Hendricks
Subject: RE: DeShazer
per ludge Martone's standing order, you are not permitted to file your own as you are the party proposing the statement,
you must set forth your statement and allow me to object and offer mine
or, add to that sentence "Beaudry RV is not a party to this lawsuit because unlike National and Freightliner, it was legally
allowed to and in fact did disclaim all warranties." A
Mar shall Meyers
Krohn & Moss, Ltd.
e-mail: [email protected]
web: wwwconsumerlawcenter com
THIS MESSAGE IS INIENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAI IS PRIVILEGED, CONFIDENTIAL AND EXEMPT y
FROM DISCLOSURE UNDER APPLICABLE LAW. [fthe reader ofthis message is not the intended recipient or agent 3
responsible tor delivering the message to the intended recipient, you are hereby notified that any dissemination or
copying ofthis communication is strictly prohibited. If you have received this electronic transmission in error, please
delete it from your system without copying it, and notify the sender by reply e—mail or by calling 602 275 5588, so that
our address record can be corrected. Thank you.
————— Original Message ----- 3
From: Shattuck, William M. [mailto:[email protected]] ·
Sent: Friday, January 27, 2006 8:35 AM
Io: Meyers, Marshall; Jack Gunn
Cc: John C. Hendricks
Subject: RE: DeShazer
It appears that the sole edit you have made was to delete the sentence "Beaudry RV is not a party to this lawsuit "
Although this is a single edit, we do not agree to it and we will file our proposed statement.
----- Original Message —--—-
From: Meyers, Marshall [mailto:mmeyers@consurnerlawcenterxcom] §
Sent: Friday, January 27, 2006 8:12 AM
Io: Shattuck, William M ; Jack Gunn I
Cc: .Iohn C. Hendricks
Subject: RE: DeShazer `
2 2
Case 2:03-cv—OO869-FJIVI Document 188-2 Filed O1/27/2006 Page 2 of 4

we do not agree, but would agree to this. let us know
Plaintiff Charles De Shazer purchased a I999 model Tradewinds motorhome from Beaudry RV in January of 1999
Defendant National RV was the final stage manufacturer ofthe motorhome, which was built on a chassis manufactured
by Defendant Freightliner Custom Chassis Corporation i
Mr· De Shazer claims that National RV breached its written warranty relating to the motorhome, and that lireightliner
breached its written warranty relating to the chassis on which the motorhome was built Mr De Shazer further claims to
have sustained damages due to National RV's and Freightliners breach of warranty for which National RV and
Freightliner are liable
National RV and lireightliner each contend that they have complied with their warranty obligations to Mr. De Shazer.
National RV and Preightliner also deny that Mr. De Shazer has sustained any damages for which they are liable
1
Marshall Meyers
Krohn & Moss, Ltd.
e-mail: mmeyer·s@consumerlawcenter com
web: wwwconsumerlawcenter.com
THIS MESSAGE IS TNTENDED ONLY POR THE USE OP THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INF ORMAIION THAT IS PRIVILEGED, CONF IDE-NTIAL AND EXEMPT T
FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient or agent I
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination or -
copying of this communication is strictly prohibited If you have received this electronic transmission in error, please L
delete it from your system without copying it, and notify the sender by reply e-mail or· by calling 602 275 5588, so that
our address record can be corrected. Thank you.
----— Original Message —————
Prom: Shattuck, William M [mailto:WMS@quar·les.com] ·
Sent: Friday, Ianuary 27, 2006 8:04 AM `
To: lack Gunn §
Cc: Meyers, Marshall; John C Hendricks -
Subject: DeShazer {
Jack--the following is the proposed Statement of the Case (as is to read to the jury) that John and I have drafted. Ifyou
agree with it then I will file it today as a stipulated statement of all the parties. If you do not agree with it then I will file ;
it today as the defendants proposed statement. Thanks. Bill Shattuck ·
Plaintiff Char les De Shazer purchased a 1999 model Tradewinds motorhome from Beaudry RV in January of 1999
Defendant National RV was the final stage manufacturer of the motorhome, which was built on a chassis manufactured
by Defendant Preightliner Custom Chassis Corporation. Beaudry RV is not a party to this lawsuit. Q
Mr De Shazer claims that National RV breached its written warranty relating to the motorhome, and that Preightliner {
breached its written warranty relating to the chassis on which the motorhome was built. Mr. De Shazer further claims to
have sustained damages due to National RV's and l*reightliner‘s breach of warranty for· which National RV and i
li reightliner are liable.
National RV and Freightliner each contend that they have complied with their warranty obligations to Mr De Shazer i
National RV and Preightliner also deny that Mr. De Shazer has sustained any damages for which they are liable j
l
Case 2:03-cv—OO869-FJIVI Document 188-2 Filed O1/27/2006 Page 3 of 4

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cannot be used, to avoid federal tax penalties. i
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r·etained only by the intended recipient. lf you have received this transmission in error, please notify the sender
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we are required to inferm you that unless we have specifically stated to the contrary in writing, any advice we provide in l
this email or any attachment concerning federal tax issues or submissions is not intended or written to be used, and T"
cannot be used, to avoid federal tax penalties.
Y
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Case 2:03-cv-00869-FJM

Document 188-2

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