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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, 1 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 Confidentiality Notice: This e-mail and any files transmitted with it are confidential and intended solely for the named addressee(s) of this message and may be subject to attorney-client privilege or work-product protection. If you are not the named addressee, unauthorized use, disclosure or distribution is prohibited; please notify the sender by reply email and destroy all copies of the original message. Our spam protection may prevent any reply e-mail from being delivered. If I have not responded to your email within 48 hours, please contact our office at 303/628-3300. This e-mail and any attachments are believed to be free of viruses and defects, but it is the responsibility of the recipient to ensure that it is virus-free. The sender is not responsible for any loss or damage arising from its use. Raymond K. Bryant I Attorney at Law Civil Group, Pi.LC 1543 Champa St., Suite 400 2 Case 1:18-cv-00217-REB-KLM Document 12-1 Filed 04/18/18 USDC Colorado Page 2 of 3 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 by law under attorney-client privilege, attorney-work-product doctrine, and/or other applicable protections. Unauthorized duplication and/or distribution is strictly prohibited. If you are not the intended recipient of this message, please forward a copy to raymond@rightslitigation.com and delete the message and its attachments from your computer. 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 by law under attorney-client privilege, attorney-work-product doctrine, and/or other applicable protections. Unauthorized duplication and/or distribution is strictly prohibited. If you are not the intended recipient of this message, please forward a copy to raymond@rightslltigation.com and delete the message and its attachments from your computer. 3 Case 1:18-cv-00217-REB-KLM Document 12-1 Filed 04/18/18 USDC Colorado Page 3 of 3