Emerson v. Wembley USA Inc. Document 108: Response to Motion, Attachment 60
Filed September 12, 2005
Back to Emerson v. Wembley USA Inc. ,
Colorado District Court
Case No. 1:03-cv-01793
RESPONSE to Motion re [102] MOTION for Summary Judgment (Renewed) and Renewed Motion for Partial Summary Judgment filed by Plaintiff Patricia A. Emerson. (Attachments: # (1) Exhibit B-1# (2) Exhibit B-2# (3) Exhibit B-3# (4) Exhibit B-4# (5) Exhibit B-5# (6) Exhibit B-6# (7) Exhibit B-7 part 1# (8) Exhibit B-7 part 2# (9) Exhibit B-8# (10) Exhibit B-9# (11) Exhibit B-10# (12) Exhibit B-11# (13) Exhibit B-12# (14) Exhibit B-13 part 1# (15) Exhibit B-13 part 2# (16) Exhibit B-13 part 3# (17) Exhibit B-13 part 4# (18) Exhibit B-13 part 5# (19) Exhibit B-13 part 6# (20) Exhibit B-13 part 7# (21) Exhibit B-14# (22) Exhibit B-15# (23) Exhibit B-16# (24) Exhibit B-17# (25) Exhibit B-18# (26) Exhibit B-19# (27) Exhibit B-20# (28) Exhibit B-21# (29) Exhibit B-22# (30) Exhibit B-23# (31) Exhibit B-24# (32) Exhibit B-25# (33) Exhibit B-26# (34) Exhibit B-27# (35) Exhibit B-28# (36) Exhibit B-29# (37) Exhibit B-30 part 1# (38) Exhibit B-30 part 2# (39) Exhibit B-30 part 3# (40) Exhibit B-30 part 4# (41) Exhibit B-30 part 5# (42) Exhibit B-31# (43) Exhibit B-32 (a) part 1# (44) Exhibit B-32 (a) part 2# (45) Exhibit B-32 (a) part 3# (46) Exhibit B-32 (a) part 4# (47) Exhibit B-32(b)# (48) Exhibit B-32 (c) part 1# (49) Exhibit B-32 (c) part 2# (50) Exhibit B-32 (c) part 3# (51) Exhibit B-32 (c) part 4# (52) Exhibit B-32 (c) part 5# (53) Exhibit B-32 (d) part 1# (54) Exhibit B-32 (d) part 2# (55) Exhibit B-32 (d) part 3# (56) Exhibit B-32 (d) part 4# (57) Exhibit B-32 (d) part 5# (58) Exhibit B-33 part 1# (59) Exhibit B-33 part 2# (60) Exhibit B-33 part 3# (61) Exhibit B-33 part 4# (62) Exhibit B-33 part 5)(Clack, Melissa)
No tags have been applied so far. Sign in to add some.
Add a Flag Add a Citation Link To Thread
Link To
-- (9/12/2003): Complaint - COMPLAINT; jury demand (gms) Modified on 09/15/2003
-- (9/12/2003): Amended Complaint - AMENDED COMPLAINT [0-1] by plaintiff; jury demand (gms)
-- (9/12/2003): Summons Returned Executed - RETURN OF SERVICE of Summons and Complaint upon defendant Wembley USA Inc. on 8/26/03 by leaving with: Jeffrey Guergen, Chief Financial Officer (gms)
-- (9/12/2003): Summons Returned Executed - RETURN OF SERVICE of Summons and Complaint upon defendant Wembley Inc. on 8/26/03 by leaving with: Jeffrey Guergen, Chief Financial Officer (gms)
-- (9/12/2003): Summons Returned Executed - RETURN OF SERVICE of Summons and Complaint upon defendant Robert Ty Howard on 8/26/03 by leaving with: Karen Gardener, Secretary/Chief Clerk (gms)
-- (9/12/2003): Summons Returned Executed - RETURN OF SERVICE of Summons and Complaint upon defendant Jefferey Goergen on 8/26/03 personally (gms)
1 (9/12/2003): Notice of Removal - NOTICE OF REMOVAL from Adams County District Court Case Number: 03CV2622 (gms)
2 (9/15/2003): Order Referring Case to Magistrate Judge - ORDER R16,stat,stlmt,pt,pto Case referred to Magistrate Judge Boyd N. Boland and General Case Management Order by Judge Edward W. Nottingham; ...
4 (9/18/2003): Answer - ANSWER by defendants to first amended complaint [0-1] (pap)
5 (9/19/2003): Rule 16 Conference - ORDER FOR RULE 16 CONFERENCE by Magistrate Judge Boyd N. Boland ; Rule 16 conference set for 10:00 10/29/03 (cc: all counsel) (pap)
6 (9/19/2003): Objections - OBJECTIONS by plaintiff Patricia A. Emerson to removal complaint [1-1] (pap)
6 (9/19/2003): Motion to Remand - Petition (MOTION) by plaintiff Patricia A. Emerson to remand case to state court, Adams County District Court (pap)
7 (9/24/2003): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland ; rule 16 conference vacated and reset for 4:00 11/6/03 ; proposed scheduling order is due on or before 10/30/03 (cc: all couns...
8 (10/10/2003): Brief in Opposition to Motion - Memorandum BRIEF by defendants in opposition to pla's motion to remand case to state court, Adams County District Court [6-1] and Request for Oral Argum...
9 (10/27/2003): Reply to Response to Motion - REPLY by plaintiff Patricia A. Emerson to dfts' memorandum brief in opposition to pla's motion to remand case to state court, Adams County District Court ...
9 (10/27/2003): Motion to Amend/Correct/Modify - and in the alternative, Request (MOTION) by plaintiff Patricia A. Emerson for leave to amend complaint [0-1] as justice so requires (pap)
10 (10/30/2003): Motion for Leave - Request (MOTION) by defendants for leave to respond to pla's "motion" for leave to amend complaint ; attached as exhibit A is Dfts' response to pla's "Motion" for l...
12 (11/7/2003): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland regarding [11-2] minutes; settlement conf set 2/9/04 3:30 and Preliminary Pretrial Conf set 3/11/04 9:00; (cc: all counsel) ; ...
13 (11/7/2003): Scheduling Order - SCHEDULING ORDER Magistrate Judge Boyd N. Boland (cc: all counsel) (pap)
14 (11/10/2003): Reply to Response to Motion - REPLY by plaintiff Patricia A. Emerson to dfts' objection to motion for leave to respond to pla's "motion" for leave to amend complaint [10-1] (pap)
15 (11/28/2003): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland ; settlement conf vacated and reset for 1:30 3/1/04 (cc: all counsel) ; entry date : 12/1/03 (pap) Modified on 12/01/2003
16 (12/5/2003): Motion for Protective Order - MOTION by defendants for protective order to protect the confidentiality of certain information, documents or things which may be discovered or produce th...
18 (12/5/2003): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion for protective order to protect the confidentiality of certain information...
17 (12/8/2003): Response to Motion - RESPONSE by plaintiff Patricia A. Emerson to dft's motion for protective order to protect the confidentiality of certain information, documents or things which may...
19 (12/9/2003): Protective Order - PROTECTIVE ORDER concerning confidential information by Magistrate Judge Boyd N. Boland : granting plas' motion for protective order to protect the confidentiality o...
20 (12/12/2003): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland ; preliminary pretrial (status) conf vacated and reset for 9:00 3/10/04 ; pto ddl reset for 3/3/04 (cc: all counsel) ; entry ...
21 (2/5/2004): Notice of Entry of Appearance - ATTORNEY APPEARANCE for defendant Jefferey Goergen by David H. Stacy (pap)
22 (2/6/2004): Motion to Continue - Stipulated MOTION by plaintiff and defendants to continue settlement conf set 3/1/04 (pap)
23 (2/9/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion to continue settlement conf set 3/1/04 [22-1] (pap)
24 (2/11/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting Stipulated motion to continue settlement conf set 3/1/04 [22-1] ; settlement conf vacated and reset for 10:30 4/26/04...
25 (2/18/2004): Motion to Withdraw as Attorney - MOTION by counsel for defendant Jefferey Goergen to withdraw attorneys Kristen L. Mix and Danielle V. Wiletsky (pap)
26 (2/18/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion to withdraw attorneys Kristen L. Mix and Danielle V. Wiletsky [25-1] (pap)
27 (2/23/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting Counsels' motion to withdraw attorneys Kristen L. Mix and Danielle V. Wiletsky [25-1]; withdrawing attorney Danielle ...
28 (3/5/2004): Motion for Leave - MOTION by plaintiff Patricia A. Emerson for leave for late endorsement of non-retained expert (treating psychologist) (pap)
29 (3/9/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion for leave for late endorsement of non-retained expert (treating psychologis...
30 (3/10/2004): Minutes-Miscellaneous - COURTROOM MINUTES by Magistrate Judge Boyd N. Boland ; pretrial (status) conf held 3/10/04 , ptch ; dfts' response shall be filed in accordance with the local r...
31 (3/10/2004): Pretrial Order - Preliminary PRE-TRIAL ORDER by Magistrate Judge Boyd N. Boland; pending motions; remaining discovery; estimated 10 day jury trial; (cc: all counsel) (pap)
32 (3/10/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland; pla shall disclose whether she asserts any claim pursuant to or under any federal statute on or before 3/16/04; (cc: all coun...
33 (3/15/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland; dfts shall respond on or before 4/2/04 regarding [28-1] motion for leave for late endorsement of non-retained expert (treatin...
34 (3/18/2004): Motion for Extension of Time - Stipulated MOTION by plaintiff and defendants for a limited extension of the discovery ddl until depositions on 4/27/04 and to reschedule the settlement ...
35 (3/19/2004): Response to Motion - RESPONSE by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion for leave for late endorsement of non-retained expert (treating psychologist) [28...
36 (3/19/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion for a limited extension of the discovery ddl until depositions on 4/27/04 ...
37 (3/22/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting stipulated motion for a limited extension of the discovery ddl until depositions on 4/27/04 [34-1], granting motion t...
38 (3/22/2004): Order - ORDER by Magistrate Judge Boyd N. Boland ; pla to show cause why this case should not be dismissed ; order to show cause ddl set for 3/30/04 (cc: all counsel) ; entry date : 3/...
39 (3/22/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting pla's motion for leave for late endorsement of non-retained expert (treating psychologist) [28-1]; motion hearing 4/6...
40 (3/29/2004): Statement - STATEMENT of Compliance by plaintiff Patricia A. Emerson re: minute order [32-1] (pap)
41 (3/30/2004): Order - ORDER by Magistrate Judge Boyd N. Boland regarding [37-2] minute order, regarding pla's [40-1] statement ; order to show cause ddl satisfied 3/30/04 and order to show cause is ...
42 (4/6/2004): Motion for Extension of Time - MOTION by plaintiff Patricia A. Emerson for extension of the discovery deadline in order to depose Mr. Bucci and review documents (pap)
43 (4/6/2004): Motion to Compel - MOTION by plaintiff Patricia A. Emerson to compel defense counsel to comply with outstanding discovery requests (pap)
44 (4/7/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion for extension of the discovery deadline in order to depose Mr. Bucci and re...
45 (4/9/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland; dfts shall respond on or before 4/28/04 regarding [43-1] motion to compel defense counsel to comply with outstanding discovery...
46 (4/9/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland ; settlement conf is vacated and reset for 1:30 6/9/04 (cc: all counsel) ; entry date : 4/12/04 (pap)
47 (4/19/2004): Motion to Continue - Unopposed MOTION by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to continue 5/11/04 hearing on motion to compel and motion for extension of the discovery...
49 (4/20/2004): Motion to Withdraw Document - Stipulated MOTION by plaintiff and defendants to withdraw motion to remand case to state court, Adams County District Court [6-1] (pap)
50 (4/20/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting Unopposed motion to continue 5/11/04 hearing on motion to compel and motion for extension of the discovery ddl [47-1]...
-- (4/21/2004): Miscellaneous Document - Tendered Pla's Second Amended Complaint submitted by plaintiff Patricia A. Emerson re: motion for leave of court to amend her complaint [0-1] to seek exemplary...
48 (4/21/2004): Motion to Amend/Correct/Modify - MOTION by plaintiff Patricia A. Emerson for leave of court to amend her complaint [0-1] to seek exemplary damages (pap)
51 (4/21/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion for leave of court to amend her complaint [0-1] to seek exemplary damages ...
52 (4/22/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland vacating and resetting hearing on motion for extension of the discovery deadline in order to depose Mr. Bucci and review docum...
53 (4/28/2004): Response to Motion - RESPONSE by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion to compel defense counsel to comply with outstanding discovery requests [43-1] (p...
54 (4/28/2004): Response to Motion - Objection (RESPONSE) by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion for extension of the discovery deadline in order to depose Mr. Bucci ...
55 (5/10/2004): Reply to Response to Motion - REPLY Brief by plaintiff Patricia A. Emerson in support of her motion for extension of the discovery deadline in order to depose Mr. Bucci and review docu...
56 (5/10/2004): Reply to Response to Motion - REPLY brief by plaintiff Patricia A. Emerson in support of her motion to compel defense counsel to comply with outstanding discovery requests [43-1] (pap)
57 (5/10/2004): Motion to Amend/Correct/Modify - MOTION by plaintiff Patricia A. Emerson to amend pre-trial order [31-1] to add a witness (pap)
58 (5/10/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion to amend pre-trial order [31-1] to add a witness [57-1] (pap)
59 (5/12/2004): Motion for Summary Judgment - MOTION by defendant Jefferey Goergen for summary judgment (gms)
60 (5/12/2004): Brief in Support of Motion - BRIEF by defendant Jefferey Goergen in support of motion for summary judgment [59-1] (gms)
61 (5/12/2004): Motion for Summary Judgment - MOTION by defendant Wembley Inc. for summary judgment (gms)
61 (5/12/2004): Motion for Partial Summary Judgment - MOTION by defendant Wembley USA Inc. for partial summary judgment (gms)
62 (5/12/2004): Brief in Support of Motion - BRIEF by Wembley Inc., Wembley USA Inc. in support of Wembley, Inc's motion for summary judgment [61-1] and Wembley USA Inc's motion for partial summary ju...
63 (5/13/2004): Motion to Compel - 2nd MOTION by plaintiff to compel responses by dfts to deposition questions (gms)
65 (5/13/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion to compel responses by dfts to deposition questions [63-1] (erv)
64 (5/14/2004): Response to Motion - Objection (RESPONSE) by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion for leave of court to amend her complaint [0-1] to seek exemplary dam...
66 (5/18/2004): Response to Motion - RESPONSE by defendant Jefferey Goergen to pla's 2nd motion to compel responses by dfts to deposition questions [63-1] (gms)
66 (5/18/2004): Motion to Strike - MOTION by defendant Jefferey Goergen to strike pla's 2nd motion to compel responses by dfts to deposition questions [63-1] and for sanctions (gms)
70 (5/18/2004): Memorandum - MEMORANDUM by Judge Edward W. Nottingham referring to Magistrate Judge Boyd N. Boland the motion to strike pla's 2nd motion to compel responses by dfts to deposition quest...
67 (5/19/2004): Order - ORDER by Magistrate Judge Boyd N. Boland granting pla's motion for extension of the discovery deadline in order to depose Mr. Bucci and review documents [42-1]. Pla to respond ...
68 (5/19/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland. Dfts to respond to pla's [57-1] motion to amend pre-trial order [31-1] to add a witness and pla's 2nd [63-1] motion to compel...
69 (5/19/2004): Amended Complaint - 2nd AMENDED COMPLAINT [0-1], [0-1] by plaintiff; jury demand (gms)
71 (5/27/2004): Motion for Extension of Time - Unopposed MOTION by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard for extension of time to respond to pla's second motion to compel and motion to...
72 (5/27/2004): Motion for Extension of Time - Unopposed MOTION by plaintiff Patricia A. Emerson for enlargement of time until 6/7/04 to reply to Goergen's response (pap)
73 (5/28/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting pla's unopposed motion for enlargement of time until 6/7/04 to reply to Goergen's response [72-1]; (cc: all counsel) ...
74 (5/28/2004): Response to Motion - RESPONSE by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's second motion to compel responses by dfts to deposition questions [63-1] (pap)
75 (5/28/2004): Order - MINUTE ORDER : by Magistrate Judge Boyd N. Boland granting Unopposed motion for extension of time to respond to pla's second motion to compel and motion to add witness until 6/...
76 (5/28/2004): Response to Motion - Objections (RESPONSE) by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion to amend pre-trial order [31-1] to add a witness [57-1] (pap)
77 (6/1/2004): Response to Motion - RESPONSE by plaintiff Patricia A. Emerson to Jeffrey Goergen's motion for summary judgment [59-1] (pap)
78 (6/1/2004): Response to Motion - RESPONSE by plaintiff Patricia A. Emerson dfts Wembley USA Inc's and Wembley Inc's motion for partial summary judgment [61-1], motion for summary judgment [61-1] (p...
79 (6/1/2004): Motion to Continue - MOTION by plaintiff for continuance pursuant to FRCP 56(f) (gms)
80 (6/3/2004): Order - ORDER by Magistrate Judge Boyd N. Boland ; settlement conf 6/9/04 is vacated (cc: all counsel) ; entry date : 6/4/04 (pap)
81 (6/7/2004): Reply to Response to Motion - REPLY brief by plaintiff Patricia A. Emerson in support of pla's second motion to compel responses by dfts to deposition questions [63-1] (pap)
82 (6/14/2004): Order - MINUTE ORDER : by Judge Edward W. Nottingham granting Stipulated motion to withdraw motion to remand case to state court, Adams County District Court [6-1] [49-1], withdrawing ...
83 (6/15/2004): Order - ORDER by Magistrate Judge Boyd N. Boland granting in part and denying in part pla's second motion to compel responses by dfts to deposition questions [63-1], supplemental disco...
84 (6/21/2004): Reply to Response to Motion - REPLY by defendant Jefferey Goergen in support of his motion for summary judgment [59-1] (pap)
85 (6/22/2004): Motion for Extension of Time - MOTION by Wembley USA Inc., Wembley Inc., Robert Ty Howard for extension of time to file reply re: their motion for sum jgm until 15 days after pla's sub...
86 (6/22/2004): Response to Motion - RESPONSE by dfts Wembley USA Inc., Wembley Inc., Robert Ty Howard to pla's motion for continuance pursuant to FRCP 56(f) [79-1] (pap)
87 (7/2/2004): Reply to Response to Motion - REPLY brief by plaintiff Patricia A. Emerson in support of her motion for continuance pursuant to FRCP 56(f) [79-1] (pap)
88 (8/16/2004): Motion to Supplement - Unopposed MOTION by plaintiff Patricia A. Emerson for leave to file pla's supplement to her motion reply [87-1] ; attached as Exhibit A is Pla's supplement to he...
89 (8/18/2004): Notice of Change of Address - NOTICE of Change of address of Kristen L. Mix counsel for Wembley USA Inc., Wembley Inc., Robert Ty Howard (pap)
90 (3/31/2005): Order on Motion for Summary Judgment - ORDER AND MEMORANDUM OF DECISION; Granting [59] Dft Goergen's Motion for Summary Judgment. Final Judgmentat the conclusion of this case will incl...
91 (5/9/2005): Order - MINUTE ORDER Status Conference is Reset for 5/19/2005 03:00 PM before Judge Edward W. Nottingham.Entered by Judge Edward W. Nottingham on 5/9/05. (pap, )
92 (5/16/2005): Motion to Withdraw as Attorney - MOTION to Withdraw Danielle V. Wiletsky as Counsel for Defendants Wembley USA Inc., Wembley Inc., Robert Ty Howard. (pap, )
93 (5/16/2005): Memorandum - MEMORANDUM referring to Magistrate Judge Boland : [92] MOTION to Withdraw as Attorney filed by Wembley USA Inc,Wembley Inc, Robert Ty Howard, by Judge Edward W. Nottingham...
94 (5/17/2005): Order on Motion to Withdraw as Attorney - MINUTE ORDER granting [92] Danielle Wiletsky's Motion to Withdraw as Attorney. Added attorney Kristen L. Mix for Robert Ty Howard; Wembley US...
-- (5/19/2005): Order on Motion for Summary Judgment - Pursuant to Status Conference [95] ORDER denying without prejudice [61] Motion for Summary Judgment and denying without prejudice [61] Motion for...
95 (5/19/2005): Status Conference - Minute Entry for proceedings held before Judge Edward W. Nottingham : Status Conference held on 5/19/2005. Denying without prejudice [61] Motion for Partial Summary...
102 (8/17/2005): Motion for Summary Judgment - MOTION for Summary Judgment (Renewed) and Renewed Motion for Partial Summary Judgment by Defendants Wembley USA Inc., Wembley Inc.. (Mix, Kristen)
103 (8/17/2005): Brief in Support of Motion - BRIEF in Support re [102] MOTION for Summary Judgment (Renewed) and Renewed Motion for Partial Summary Judgment filed by Defendants Wembley USA Inc., Wemb...
105 (8/29/2005): Motion for Extension of Time to File Response/Repl - MOTION for Extension of Time to File Response/Reply as to [102] MOTION for Summary Judgment (Renewed) and Renewed Motion for Par...
106 (8/30/2005): Order - MINUTE ORDER Re: [104] Status Report filed by Defendants: A Status Conference is scheduled for Friday, September 16, 2005 commencing at 02:45 PM in Courtroom A1001 before Judg...
107 (8/31/2005): Order on Motion for Extension of Time to File Resp - MINUTE ORDER: Plaintiff's [105] Motion for Extension of Time to Respond to Defendants' Renewed [102] MOTIONS for Summary Judgment ...
Jump to Document 108 or Attachment 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63
There was a problem processing the raw text for this document.