Case 1:03-cv-01654-MSK-MEH
Document 163
Filed 11/16/2005
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-1654-MSK-OES RONAN TYNAN, an individual Plaintiff, v. THE BROADMOOR HOTEL, INC., a Colorado corporation; Defendant.
DEFENDANT BROADMOOR HOTEL'S OBJECTIONS AND CROSS-DESIGNATIONS TO DEPOSITION TESTIMONY FOR KEITH SYNOTT, FRCSI
Defendant, THE BROADMOOR HOTEL, INC., by and through its attorneys, OVERTURF & McGATH, P.C., and pursuant to Fed.R.Civ.P. 26(a)(3)(C) hereby objects and cross-designates the deposition testimony of Andrew Synott, FRCSI, as follows: OBJECTIONS PAGE/LINE 6:13-20 28:16-8 29:2-24 30:3-5, 13-17 30 31:9 BASIS FOR OBJECTION This designation is taken out of context. Dr. Synott is not endorsed as an expert Dr. Synott is not endorsed as an expert Dr. Synott is not endorsed as an expert This reference is not a proper designation, appears to be duplicative, there is no proper foundation to the medline research on pp. 30 31, the information is hearsay, and there is no specific reference to the studies referred to by Dr. Synott
Case 1:03-cv-01654-MSK-MEH
Document 163
Filed 11/16/2005
Page 2 of 2
32: 7-11
Dr. Synott is not endorsed as an expert and a portion of this testimony is non responsive.
CROSS-DESIGNATIONS 11:23 12:25 17:15 19:2 and 18:13 19:13 should be combined as 17:15 19:13 Respectfully submitted this 16th day of November, 2005. OVERTURF & McGATH, P.C. /s/ Richard K. Rediger
__________________________________________ Richard K. Rediger 625 E. 16th Avenue, Suite 100 Denver, CO 80203 303.860.2848 (ph) 303.860.2869 (fax) [email protected] Attorney for Defendant The Broadmoor Hotel, Inc. CERTIFICATE OF SERVICE I hereby certify that on this 16th day of November, 2005, I electronically filed the DEFENDANT BROADMOOR HOTEL'S OBJECTIONS AND CROSS-DESIGNATIONS TO DEPOSITION TESTIMONY FOR KEITH SYNOTT, FRCSI with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following counsel: David G. Palmer, Esq. Brian L. Duffy, Esq. Naomi G. Beer, Esq. GREENBURG TRAURIG LLP 200 17th Street, Suite 2400 Denver, CO 80202 /s/ Trish Schart
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