Free Objections - District Court of Colorado - Colorado

Case 1:02-cv-01957-PSF-MEH

Document 92

Filed 12/27/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 02-cv-1957-PSF-OES JOHN M. LONGO, Plaintiff, v. REGIS JESUIT HIGH SCHOOL CORPORATION D/B/A REGIS JESUIT HIGH SCHOOL, Defendant. ______________________________________________________________________________ PLAINTIFF'S OBJECTIONS TO DEFENDANT'S EXHIBITS ______________________________________________________________________________ A. B. C. D. E. F. G. H. Application and related documents. Stipulated. Faculty Handbook, Fall, 1998. Stipulated. 2000-2001 Faculty Handbook Addendum. Stipulated. Regis Jesuit High School Faculty Handbook 2003. Objections: 401, 402, 403. Restated and Amended Articles of Incorporation March 15, 1995. Stipulated. 2001 Faculty Development Goals. Stipulated. Charge of Discrimination dated June 30, 2001. Stipulated. Notification of charge of alleged discrimination letter from Colorado Civil Rights Division to Regis Jesuit High School. Objection: 401, 402, 403. I. Regis Jesuit High School's Response to Charge of Discrimination to Colorado Civil Rights Division dated October 12, 2001, with exhibits. Objections: 401, 402, 403, 802.

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J.

John Longo's Reply to Regis Jesuit High School's Response to Charge of Discrimination to Colorado Civil Rights Division dated December 10, 2001, with exhibits. Stipulated with Affidavit which was included with Reply, objection to offer without Affidavit.

K.

Determination from Colorado Civil Rights Division Dated July 18, 2002: Objections: 401, 402, 403, 802.

L.

EEOC Dismissal and Notice of Rights dated August 29, 2002. Stipulated, with finding redacted.

M. N.

EEOC/FEPA Investigation Form. Objection: 401, 402, 403. Letter from Colorado Division of Workers Compensation dated June 11, 2004. Objection, 401, 402, 403.

O.

Medical Records from Arapahoe Internal Medicine/Dr. Charles Lee. Objections: 401, 402, 403, 802, 901.

P.

Medical Records of Plaintiff from Colorado Eye Site/Dr. Alan Margolis. Objections: 401, 402, 403, 802, 901.

Q.

Theology Department Course Benchmarks dated August 14, 2001. Objections: 401, 402, 403.

R. S. T. U. V.

Triple Choice Dental Plan Employee Packet. Stipulated. PacifiCare of Colorado Health Plan. Stipulated. Fortis Benefits Insurance Company Life Insurance. Stipulated. Regis Jesuit High School Defined Contribution Plan Document January 2003. Stipulated. Standard Insurance Company Group Long Term Disability Insurance. Stipulated. 2

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W. X. Y.

Regis Jesuit High School Section 125 Flexible Benefit Plan. Stipulated. Regis Jesuit High School Kairos Retreat Information. Objections: 401,402, 403. Regis University School for Professional Studies Course Consultant Stipend Payment Forms and copies of checks. Objections 401, 402, 403.

Z. A-1.

Voucher Inquiries. Objections, 401,402, 403. Letter to Regis University from John Longo re application for part-time work dated May 15, 2001. Stipulated.

A-2. A-3.

John Longo's resume. Stipulated. Letter to John Longo from Regis University dated June 12, 2001. Objections 401,402, 403, 802.

A-4. A-5. A-6. A-7.

John Longo's transcripts. Objections: 401,402, 403. Facilitator Candidate Resume dated April 6, 2001. Objections: 401,402, 403, 802, 901. Regis University Interview Evaluation Form. Objections: 401, 402, 403, 404, 802, 901. Regis University Instructional Facilitation Evaluation Forms Objections: 401, 402, 403, 404, 802.

A-8. A-9.

Regis University Group Activity Evaluation Forms. Objections: 401, 402, 403, 404, 802. Regis University Assessment Question and Answer. Objections: 401, 402, 403.

A-10. E-mails regarding assessment results dated August 22, 2001, and August 23, 2001. Objections: 401, 402, 403, 404, 802. A-11. Raider review issues. Objections: this endorsement is not specific enough to allow identification of the exhibits to be offered, and therefore violates the Court's pre-trial 3

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order instructions. Further objection, 401, 402, 403, and with reservation of rights to make further objection when and if specific documents are identified. A-12. Lines of Authority Graph for Regis Jesuit High School. Stipulated. A-13. Regis Jesuit High School Brochure. Objection: 401, 402, 403. A-14. Acknowledgment form re receipt of Faculty Handbook. Stipulated. A-15. First Semester Post-Conference Summary dated December 9, 1999. Stipulated. A-16 Second Semester Post-Conference Summary dated February 11, 2000. Stipulated. A-17. Summary by Sister Pat of October 11, 2000 observation. Stipulated. A-18. First Semester Post-Conference Summary dated October, 2000. Stipulated. A-19. First Semester Supervision Post-Conference Summary dated October 24, 2000. Stipulated. A-20. Letter to Joe from John Longo dated October 24, 2000. Stipulated. A-21. Meeting note dated December 8, 2000. Objection: 802. A-22. Letter to John Longo from Susan Resnick dated January 18, 2001. Stipulated. A-23. Observation Analysis Form dated January 31, 2001. Objection: 401, 402, 403, 802. A-24. Letter to Susan Resnick from John Longo, January 18, 2001. Stipulated. A-25. Observation analysis Form dated February 14, 2001. Objections: 401, 402, 403. 802. A-26. Memo to Kathleen Tanner from John Longo dated February 2, 2001. Memo, stipulated. Notes, objection, 401, 402, 403, 802. A-27. Memo to John Longo from Kathleen Tanner dated February 8, 2001. Stipulated. A-28. Print-out of list of unread e-mails. Objection: 802 4

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A-29. Observation summary from Sister Pat dated February 13, 2001. Memo Stipulated. Notes, objection, 401, 402, 403, 802. A-30 Memo to Kathleen Tanner from John Longo dated February 21, 2001. Stipulated.

A-31. Memo to Sister Pat from John Longo dated February 21, 2001. Stipulated. A-32. Memo to Mr. Saulino from John Longo dated February 23, 2001. Stipulated. A-33. Memo to Kathleen Tanner from John Longo dated February 26, 2001. Stipulated. A-34. Memo to Sister Pat from John Longo dated February 26, 2001. Stipulated. A-35. Memo to Father from Susan re John Longo's non-renewal. Stipulated. A-36. Letter to John Longo from Charlie Saulino dated April 18, 2001. Stipulated. A-37. Memo to Charlie Saulino from John Longo dated May 23, 2001. Stipulated. A-38. Parent & Student complaints about John Longo's teaching. Objections: 401, 402, 403, 802, 901. A-39. Attendance sheets. Objections: 401, 402, 403, 802, 901. A-40. Disciplinary referral sheets. Objections: 401, 402, 403, 802, 901 A-41. Letter to John Longo from Rick Sullivan dated March 1, 2000. Stipulated. A-42. Regis Jesuit High School Faculty Contract of Employment - 2000-2001. Contract, Stipulated. Objection to attachment of handbook page. A-43 403. A-44. Tape 1 From Plaintiff. Objections: 401, 402, 403, 802, 901. Regis Jesuit High School Standards for Professional Teaching. Objections: 401, 402,

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A-45. Tape 2 from Plaintiff. Objections: 401, 402, 403, 802, 901. This tape as provided to counsel for Plaintiff was blank. Plaintiff reserves the right to change or add to these objections when and if a tape with any content is provided. A-46. Tape 3 from Plaintiff. Objections: 401, 402, 403, 802, 901. A-47. Tape 4 from Plaintiff. Objections: 401, 402, 403, 802, 901. A-48. Letter to John Longo from Susan Resnick dated December 19, 2000. Stipulated. A-49. Composite exhibits from W. Kaempfer deposition. Tax returns: stipulated. Other documents, objections 401, 402, 403, 802. A-50. Longo's tax and W-2 forms. Stipulated. A-51. Memo to Sister Pat from John Longo dated February 2, 2001. Stipulated. A-52. Memo to Sister Pat from John Longo dated December 20, 2000. Stipulated. A-53. Faculty Development Goals for John Longo, undated. Stipulated. A-54. Letter to Charlie from John Longo dated January 11, 2001. Stipulated. A-55. Memo to Charlie Saulino from John Longo dated April 2, 2001. Stipulated. A-56. Memo to Kathleen Tanner from John Longo, undated, re JAWS. Stipulated. A-57 Tech Training Wednesday April 4 flyer. Stipulated. A-58. Moral Leadership research paper. Stipulated. A-59. Index to Braille documents. Objections: 401, 402, 403, 802.

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Exhibits used in Depositions in this matter. Objections: this endorsement is not specific enough to allow identification of the exhibits, and violates the Court's pre-trial order instructions, which specifically state that this type of endorsement is unacceptable.

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All documents produced in response to discovery or through disclosure by either party. Objections: this endorsement is not specific enough to allow identification of the exhibits, and violates the Court's pre-trial order instructions, which specifically state that this type of endorsement is unacceptable.

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Any exhibit that becomes known through disclosure or discovery in this matter. Objections: this endorsement is not specific enough to allow identification of the exhibits, and violates the Court's pre-trial order instructions, which specifically state that this type of endorsement is unacceptable.

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Any exhibit necessary for the purpose of impeachment and/or rebuttal. Right to object reserved.

Submitted this 19th day of December, 2005.

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Case 1:02-cv-01957-PSF-MEH

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CERTIFICATE OF SERVICE The undersigned certifies that on the 19th day of December, 2005, a copy of the foregoing PLAINTIFF'S OBJECTIONS TO DEFENDANT'S EXHIBITS was placed in the United States Mail, postage prepaid, and addressed to: Michael G. Bohn, Esq. Brett M. Heidemann, Esq. Elizabeth Beebe Volz, Esq. Campbell Bohn Killin Brittan & Ray LLC 270 St. Paul Street, Suite 200 Denver, CO 80206 and that on December 27, 2005, PLAINTIFF'S OBJECTIONS TO DEFENDANT'S EXHIBITS were electronically filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected]; [email protected]; [email protected]

______________________________ s/Laurie Scott Paddock 1756 Gilpin Street Denver, CO 80218 Telephone: 303-863-0071 Fax: 303-394-4126 [email protected]

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