NOTICE Of Filing Of Plaintiff's Response To Wembley Inc.'s And Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci by Plaintiff Patricia A. Emerson (Attachments: # (1) Exhibit 1: Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (2) Exhibit A: Part 1 to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (3) Exhibit A: Part 2 to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (4) Exhibit A: Part 3 to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (5) Exhibit A: Part 4 to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (6) Exhibit B to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (7) Exhibit C to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (8) Exhibit D to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (9) Exhibit E to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (10) Exhibit F to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (11) Exhibit G to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.# (12) Exhibit H to Response To Wembley Inc.'s and Wembley USA, Inc.'s Motion To Compel Answers To Deposition Questions By Witness Dan Bucci.)(Clack, Melissa)
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| Case 1:03-cv-01793-EWN-BNB Document 127 Filed 02/27/2006 Page 1of3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Edward W. Nottingham
> Civil Action No. 03-CV-01793-EWB-BNB | PATRICIA EMERSON, Plaintiff, —_ WEMBLEY USA INC.; WEMBLEY INC.; ROBERT TY HOWARD in his personal capacity; and JEFFREY GOERGEN in his personal capacity, Defendants.
NOTICE OF FILING OF PLAINTIFF’S RESPONSE TO WEMBLEY INC.’S AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO ‘DEPOSITION QUESTIONS BY WITNESS DAN BUCCI ,
‘Plaintiff Patricia Emerson, through counsel Zupkus and Angell, P.C., hereby submits the following Notice of Filing, stating as follows: | |
1. On February 8, 2006, Defendants 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. Defendants submitted their Motion To Compel to the District of Rhode Island because Mr. Bucci resides there and his deposition was taken in that District, See Notice of Filling of Defendants Wembley, Inc.’s and Wembley USA, Inc.’s Motion To Compel. Defendants further submitted a Notice of Filing to the U.S. District Court for the District of Colorado, on the basis that a ruling on Defendants’
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Case 1:03-cv-01793-EWN-BNB Document 127 ~~ Filed 02/27/2006 Page 2of3
Motion’ To Compel may affect this Court’s decision on Defendant’s pending Motion For Summary Judgment.
3. Plaintiff filed her Response to Defendants’ Motion To Compel with the USS. District Court for the District of Rhode Island on February 27, 2006, Plaintiff hereby attaches a copy of the Plaintiff's Response to Defendants’? Motion To Compel for the Court’s convenience.
4. In her Response, Plaintiff requests that Defendants’ Motion To Compel be denied, because a second deposition of Mr. Bucci would be an undue burden upon the Plaintiff, and because Mr. Bucci had a reasonable basis for pleading the Fifth
Amendment during his deposition.
Respectfully submitted this 27" day of February, 2006.
ZUPKUS & ANGELL, P.C.
S/Melissa Clack Robert Zupkus Melissa A. Clack Zupkus & Angell, P.C.
Case 1:03-cv-01793-EWN-BNB_ Document 127 Filed 02/27/2006 Page 3of3 CERTIFICATE OF SERVICE I hereby certify that on this 27" day of February 2006, I electrically filed the foregoing NOTICE OF FILING OF PLAINTIFF’S RESPONSE TO WEMBLEY INC.’S AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS BY WITNESS DAN BUCCI, with the Clerk of Court via EFC and will send notification of such filing to the following email addresses: kmix@swlaw.com Kristen L. Mix, Esq.
Snell & Wilmer 1200 Seventeenth Street, Suite 1900 The Tabor Center Denver, CO 80202 s/Crystal Littrell FOR ZUPKUS & ANGELL, P.C.
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| Case 1:03-cv-01793-EWN-BNB Document 127 Filed 02/27/2006 Page 1of3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Judge Edward W. Nottingham
> Civil Action No. 03-CV-01793-EWB-BNB
| PATRICIA EMERSON,
Plaintiff,
—_
WEMBLEY USA INC.;
WEMBLEY INC.;
ROBERT TY HOWARD in his personal capacity; and
JEFFREY GOERGEN in his personal capacity,
Defendants.
NOTICE OF FILING OF PLAINTIFF’S RESPONSE TO WEMBLEY INC.’S
AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO
‘DEPOSITION QUESTIONS BY WITNESS DAN BUCCI ,
‘Plaintiff Patricia Emerson, through counsel Zupkus and Angell, P.C., hereby
submits the following Notice of Filing, stating as follows: | |
1. On February 8, 2006, Defendants 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. Defendants submitted their Motion To Compel to the District of Rhode
Island because Mr. Bucci resides there and his deposition was taken in that District,
See Notice of Filling of Defendants Wembley, Inc.’s and Wembley USA, Inc.’s
Motion To Compel. Defendants further submitted a Notice of Filing to the U.S.
District Court for the District of Colorado, on the basis that a ruling on Defendants’
PDF Page 3
Case 1:03-cv-01793-EWN-BNB Document 127 ~~ Filed 02/27/2006 Page 2of3
Motion’ To Compel may affect this Court’s decision on Defendant’s pending Motion
For Summary Judgment.
3. Plaintiff filed her Response to Defendants’ Motion To Compel with the
USS. District Court for the District of Rhode Island on February 27, 2006, Plaintiff
hereby attaches a copy of the Plaintiff's Response to Defendants’? Motion To Compel
for the Court’s convenience.
4. In her Response, Plaintiff requests that Defendants’ Motion To Compel be
denied, because a second deposition of Mr. Bucci would be an undue burden upon the
Plaintiff, and because Mr. Bucci had a reasonable basis for pleading the Fifth
Amendment during his deposition.
Respectfully submitted this 27" day of February, 2006.
ZUPKUS & ANGELL, P.C.
S/Melissa Clack
Robert Zupkus
Melissa A. Clack
Zupkus & Angell, P.C.
555 E. 8th Avenue
Denver, Colorado 80202
Telephone: (303) 894-8948
Fax: (303) 894-0104
Email: rzupkus@zalaw.com
Email: bshefrin@zalaw.com
Email: mclack@zalaw.com
Attorneys for Plaintiff Patricia Emerson
PDF Page 4
Case 1:03-cv-01793-EWN-BNB_ Document 127 Filed 02/27/2006 Page 3of3
CERTIFICATE OF SERVICE
I hereby certify that on this 27" day of February 2006, I electrically filed the foregoing
NOTICE OF FILING OF PLAINTIFF’S RESPONSE TO WEMBLEY INC.’S
AND WEMBLEY USA, INC.’S MOTION TO COMPEL ANSWERS TO
DEPOSITION QUESTIONS BY WITNESS DAN BUCCI, with the Clerk of Court
via EFC and will send notification of such filing to the following email addresses:
kmix@swlaw.com
Kristen L. Mix, Esq.
Snell & Wilmer
1200 Seventeenth Street, Suite 1900
The Tabor Center
Denver, CO 80202
s/Crystal Littrell
FOR ZUPKUS & ANGELL, P.C.
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