HomeMy WebLinkAbout2018CV217 - MONTGOMERY V. CHERNAK, HOWARD & BROUGH - 012A - EXHIBIT AGunn, Christina S.
From:
Sent:
To:
Cc:
Subject:
We oppose.
Raymond Bryant < raymond@rightslitigation.com>
Monday, April 16, 2018 1:42 PM
Gunn, Christina S.
Lyons, Thomas J.; Marion, Nicole
Re: Montgomery - Conferral for Motion to Stay Discovery
On Mon, Apr 16, 2018 at 1:28 PM, Gunn, Christina S.<gunnc@hallevans.com> wrote:
Mr. Bryant,
I would like to file the Motion for a Stay of Discovery; please let me know your position.
Thanks,
Christina Gunn
Christina S. Gunn I Member
gunnc@hallevans.com
Tel: 303-628-3492
Hall & Evans, LLC
1001 Seventeenth Street, Suite 300
Denver, CO 80202
H:I ~~~R~~~y~~.~LLC
DFNVFR, CO I 81LUNGS, MT I LARMr11F, WY
website I bio I Linkedln I map
From: Raymond Bryant [mailto:raymond@rightslitigation.com]
Sent: Wednesday, April 11, 2018 9:27 AM
To: Gunn, Christina S.<gunnc@hallevans.com>
Cc: Lyons, Thomas J. <lyonst@hallevans.com>; Marion, Nicole <marionn@hallevans.com>
Subject: Re: Montgomery - Conferral for Motion to Stay Discovery
Christina,
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Case 1:18-cv-00217-REB-KLM Document 12-1 Filed 04/18/18 USDC Colorado Page 1 of 3
Let me get back to you about this Monday. I have not yet had a chance to review the motion to dismiss in detail. If
there are defects that can be addressed with an amendment, any amendment we file will moot out the motion and
your basis for a request to stay.
On Tue, Apr 10, 2018 at 9:54 AM, Gunn, Christina S. <gunnc@hallevans.com> wrote:
Mr. Bryant,
Defendants intend to file a Motion to Stay Discovery pending ruling on Defendants' Motion to Dismiss due to
Defendants' assertion of a qualified immunity defense to each of Plaintiffs claims. Please advise of Plaintiffs
position related to this request for purposes of Local Rule 7.1 conferral.
Thanks,
Christina Gunn
Christina S. Gunn I Member
gunnc@hallevans.com
Tel: 303-628-3492
Hall & Evans, LLC
1001 Seventeenth Street, Suite 300
Denver, CO 80202
DE~JVER, co I BILLINGS, MT I L!\Ri\i\111E, WY
website I bio I Linkedln I map
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Raymond K. Bryant I Attorney at Law
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Raymond K. Bryant I Attorney at Law
Civil Rights litigation Group, PLLC
1543 Champa St., Suite 400
Denver, CO 80202
Phone: (720) 515-6165
Fax: (720) 465-1975
NOTICE: This e-mail message is directed to the above-identified recipients only and may contain confidential information that is protected
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raymond@rightslltigation.com and delete the message and its attachments from your computer.
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