NOTICE of Filing of Motion to Compel by Defendants Wembley USA Inc., Wembley Inc. (Attachments: # (1) Exhibit Defendants' Motion to Compel# (2) Exhibit A-17 Bucci Deposition Excerpts# (3) Exhibit Exhibit B-34 Bucci Deposition Excerpts# (4) Exhibit Exhibit C Plaintiff's Response to Second Renewed MSJ# (5) Exhibit Exhibit D Wilson v. Armco# (6) Exhibit Exhibit E In re Arizona Bakery Products)(Mix, Kristen)
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Case 1:03-cv-01793-EWN-BNB Document 122 Filed 02/10/2006 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-01793-EWN-BNB PATRICIA A. EMERSON, Plaintiff, v.
WEMBLEY USA, INC.; WEMBLEY INC.;
ROBERT TY HOWARD in his personal capacity; and JEFFREY GOERGEN in his personal capacity, Defendants.
______________________________________________________________________________ NOTICE OF FILING OF DEFENDANTS WEMBLEY, INC.’S AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS BY WITNESS DAN BUCCI ______________________________________________________________________________ Defendants Wembley, Inc. and Wembley USA, Inc. (collectively, the “Wembley Defendants”), through their attorney Kristen L. Mix of Snell & Wilmer L.L.P., respectfully submit the following Notice of Filing, stating as follows:
1.
Defendants recently filed a Motion to Compel Answers to Deposition Questions by Witness Dan Bucci in the United States District Court for the District of Rhode Island. 2.
Pursuant to F.R.C.P. 37(a)(1), the District of Rhode Island is the appropriate court in which to file such a motion because Mr. Bucci resides there and his deposition was taken in that District.
3.
As the District of Rhode Island’s ruling on the Motion to Compel may have some impact on this Court’s decision regarding Defendants’ Second Renewed Motion for Summary 102599.1
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Judgment and Motion for Partial Summary Judgment filed December 9, 2005, attached hereto for the Court’s convenience is a copy of the Motion to Compel, with exhibits. As the Court will note, Defendants have requested an Order compelling Mr. Bucci to answer the questions propounded to him during his deposition, or, in the alternative, that the District Court for the District of Rhode Island transfer jurisdiction over the Motion to Compel to this Court.
Respectfully submitted this 10th day of February, 2006.
Respectfully submitted,
s/Kristen L. Mix Kristen L. Mix SNELL & WILMER L.L.P.
1200 Seventeenth Street, Suite 1900 Denver, Colorado 80202 Telephone: (303) 634-2000 Facsimile: (303) 634-2020 ATTORNEYS FOR DEFENDANTS WEMBLEY USA, INC., WEMBLEY, INC., AND ROBERT TY HOWARD
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CERTIFICATE OF SERVICE
The undersigned does hereby certify that on this 10th day of February, 2006, a true and correct copy of the foregoing NOTICE OF FILING OF DEFENDANTS WEMBLEY, INC.’S AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS BY WITNESS DAN BUCCI was served via ECF electronic filing on the following:
Attorneys for Plaintiff Bradley N. Shefrin, Esq.
Melissa Clack, Esq.
ZUPKUS & ANGELL, PC
555 E. 8th Ave.
Denver, CO 80203 Telephone: 303-894-8948 Facsimile: 303-894-0104 Attorneys for Defendant Jeffrey Goergen David H. Stacy, Esq.
DUCKER MONTGOMERY & ARONSTEIN, P.C. 1560 Broadway, Suite 1400 Denver, CO 80202-5151 Telephone: (303) 228-2529 Facsimile: (303) 861-4017
By U. S. Mail to:
Attorneys for Daniel Bucci Anthony M. Traini, Esq.
55 Pine St., Ste. 5 Providence, RI 02903-2841 401-621-4700 /s Martha McCleery Martha McCleery
102599.1
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 03-cv-01793-EWN-BNB
PATRICIA A. EMERSON,
Plaintiff,
v.
WEMBLEY USA, INC.; WEMBLEY INC.;
ROBERT TY HOWARD in his personal capacity;
and JEFFREY GOERGEN in his personal capacity,
Defendants.
______________________________________________________________________________
NOTICE OF FILING OF DEFENDANTS WEMBLEY, INC.’S AND WEMBLEY USA,
INC.’S MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS
BY WITNESS DAN BUCCI
______________________________________________________________________________
Defendants Wembley, Inc. and Wembley USA, Inc. (collectively, the “Wembley
Defendants”), through their attorney Kristen L. Mix of Snell & Wilmer L.L.P., respectfully
submit the following Notice of Filing, stating as follows:
1.
Defendants recently filed a Motion to Compel Answers to Deposition Questions
by Witness Dan Bucci in the United States District Court for the District of Rhode Island.
2.
Pursuant to F.R.C.P. 37(a)(1), the District of Rhode Island is the appropriate court
in which to file such a motion because Mr. Bucci resides there and his deposition was taken in
that District.
3.
As the District of Rhode Island’s ruling on the Motion to Compel may have some
impact on this Court’s decision regarding Defendants’ Second Renewed Motion for Summary
102599.1
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Judgment and Motion for Partial Summary Judgment filed December 9, 2005, attached hereto
for the Court’s convenience is a copy of the Motion to Compel, with exhibits. As the Court will
note, Defendants have requested an Order compelling Mr. Bucci to answer the questions
propounded to him during his deposition, or, in the alternative, that the District Court for the
District of Rhode Island transfer jurisdiction over the Motion to Compel to this Court.
Respectfully submitted this 10th day of February, 2006.
Respectfully submitted,
s/Kristen L. Mix
Kristen L. Mix
SNELL & WILMER L.L.P.
1200 Seventeenth Street, Suite 1900
Denver, Colorado 80202
Telephone: (303) 634-2000
Facsimile: (303) 634-2020
ATTORNEYS FOR DEFENDANTS
WEMBLEY USA, INC., WEMBLEY, INC.,
AND ROBERT TY HOWARD
102599.1
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CERTIFICATE OF SERVICE
The undersigned does hereby certify that on this 10th day of February, 2006, a true and correct
copy of the foregoing NOTICE OF FILING OF DEFENDANTS WEMBLEY, INC.’S AND
WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO DEPOSITION
QUESTIONS BY WITNESS DAN BUCCI was served via ECF electronic filing on the
following:
Attorneys for Plaintiff
Bradley N. Shefrin, Esq.
Melissa Clack, Esq.
ZUPKUS & ANGELL, PC
555 E. 8th Ave.
Denver, CO 80203
Telephone: 303-894-8948
Facsimile: 303-894-0104
Attorneys for Defendant Jeffrey Goergen
David H. Stacy, Esq.
DUCKER MONTGOMERY & ARONSTEIN, P.C.
1560 Broadway, Suite 1400
Denver, CO 80202-5151
Telephone: (303) 228-2529
Facsimile: (303) 861-4017
By U. S. Mail to:
Attorneys for Daniel Bucci
Anthony M. Traini, Esq.
55 Pine St., Ste. 5
Providence, RI 02903-2841
401-621-4700
/s Martha McCleery
Martha McCleery
102599.1
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