Free Other Notice - District Court of Arizona - Arizona

SOUTHERN UNITED
EXHIBITS / ATTACHMENT "B"
Plaintiff’s Objections:
A Plaintiff has no objection to correspondence between Southern United and Steven
Schneider being admitted as a whole, and has listed Southern United’s claim {ile
as an exhibit to be admitted which contains such correspondence. To the extent
that Defendants will not agree to the admission of all such correspondence as a
whole, however, Plaintiff objects to the admission of Defendant’s selected
portions of the correspondence as misleading, incomplete, and out of context, and
reserves all objections to such letters and other individual documents from the
claim file, including relevance, and Rule 403.
B Plaintiff has no objection to the admission of the entire files in this matter of
attorneys Steven Schneider, Stephen Kimble, and William Wilder, nor the
Hartford claim file, and Plaintiff has listed those as exhibits. To the extent that
Defendants will not agree to that, however, Plaintiff objects to the admission of
their selected individual documents for those files as incomplete, misleading, and
out of context, and Plaintiff reserves all objections to those exhibits in isolation,
including relevance and Rule 403.
STIPULATED OBJECTION
l· August 1, 2001 letter from Lisa Harrell to Steven A
Schneider. (Schneider Exh. 6.).
2· October 2, 2001 letter from Lisa Harrell to Steven A
Schneider. (Hernandez Exh. 2.).
3· Agreement (Covenant Not To Execute) dated A, B
December 21, 2001. (Schneider Exh. 14.).
4- Letter from Stephen Kimble to Steven Schneider A, B
dated January 17, 2003, enclosing check.
(Schneider Exh. 20.).
5· Patricia Hernandez — Underinsured Motorist
Settlement disbursement (Hernandez Exh. 2.).
6· Release and Settlement of Claim dated December A,B
21, 2001 (Hernandez Exh. 11.).
Exhibit B to Joint Pretrial — Page 1
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SOUTHERN UNITED
EXHIBITS / ATTACHMENT "A"
7- Letter from Pam Gilbert to Steven Schneider dated A
April 29, 2002. (Hernandez Exh. 13.).
8- Letter from Steven Schneider to Pam Gilbert dated A
April 29, 2002. (Hernandez Exh. 14.).
9- General Agency Agreement. (Rollins Exh. 1.). X _
10- Letter from Steven Schneider to William Wilder
dated October 16, 2001 (Wilder Exh. 4.).
11- Letter from Steven Schneider to William Wilder
dated December 4, 2001. (Wilder Exh. 5.).
12- Letter from Steven Schneider to William Wilder
dated December 26, 2001 (Wilder Exh. 7.).
13- Letter from Robert Austin to John Crotty dated May
16, 2002. (Wilder Exh. 16.).
14- Letter from John Crotty to Lisa Harrell dated April A
23, 2002. (Freberg Exh. 18.).
15- Letter from Bruce Demaree to John Crotty dated
July 1, 2002. (Freberg Exh. 20.).
16- Hartford Activity Log. (Freberg Exh. 21.).
17- April 30, 2002 letter from Stephen Kimble to Steven
Schneider. (Kimble Exh. 3.).
18- Letter from Stephen Kimble to John Crotty
dated May 9, 2002 (Kimble Exh. 5.).
19- Letter from Stephen Kimble to John Crotty
dated July 29, 2002. (Kimble Exh. 8.).
20- Letter from Stephen Kimble to Scott Alles
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SOUTHERN UNITED
EXHIBITS / ATTACHMENT "A"
dated odtdber 30, 2002. (Kimbie Exh. 15.). __
21- Southern United Claim File Activity Notes. (With A
infomation on reserves and attorney client
privileged information redacted)
Defendants reserve the right to use all exhibits
designated by Plaintiff.
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