Free Notice (Other) - District Court of Colorado - Colorado

Case 1:02-cv-01977-RPM

Document 96-4

Filed 05/23/2006

Page 1 of 1

Tom McMahon
From: Sent: To: Cc: Subject: Larry Theis [[email protected]] Thursday, May 18,2006 12:36 PM Tom McMahon 'Randy Berger (E-mail)' RE: Class Def Clarification

We have reviewed the proposed stipulation with our client. Since we are opposed to the certification of any class in this matter, we are not inclined to "stipulate" to anything with regard to your definition. Our preference is to review whatever you might ultimately file with the court and take a position with regard to any proposed modification or clarification at that time.

----- Original Message----From: Tom McMahon [mailto:[email protected]] Sent: Thursday, May 18, 2006 10:55 AM To: Larry Theis (E-mail) Cc: Randy Berger (E-mail) Subject: Class Def Clarification
Larry -- I left a voice-mail msg for you yesterday, then Randy and I just tried to call you this morning, to discuss the class definition clarification addressed in my May 2nd ltr to you and which you and Randy discussed at the Hayes rebuttal depo. I am going to be tied up with clients the rest of the day, so am sending you and Randy a draft stip. that I have worked up in consultation with Randy. Pls call him (888-529-4787) to discuss. Thx. -- Tom

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