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FROM :AGO NAT. RES. SECTION TO 1 303 2410336 1995.02-13 08:25 #074 P.06/06 <br /> i <br /> �c <br /> GALE A.Norton STATE OF COLORADO STATE SUMCM SUILDM <br /> Attorney General 1525 Sherman Street-Sth <br /> DEPART> M OF LAW Floor <br /> 5T1BP iEN M E:F $RAcK Deaver Colorado 80203 <br /> Chic F Deputy Attorney Gmeml OFFICE OF THE ATTORNEY GENERAL phone 303 866-4500 <br /> TI 40TE2Y M.TYMH,OVICH FAX �303)j 866-5591 <br /> Solicitor General February 10, 1995 <br /> VIA FACSIMILE <br /> Joel W. cantrick <br /> Robbin A. Lego <br /> Pendleton & Sabian, P.G. <br /> 303 East 17th Avenue <br /> Suite 1000 <br /> Denver, Colorado 80203 <br /> RE: DMG v. Reeves. at Al. <br /> Dear Joel and Robbin: <br /> I have received your fax of February 7, 1995, about the <br /> scheduling of depositions of the defendants. As you know, <br /> discovery in this case must be completed by March 30, and on <br /> March 27, we have the motions hearing scheduled. You have <br /> informed me that Robert and Diane' Delaney will be gone for two <br /> seeks (the weeks of February 27 and March 6) , and that Joel is <br /> scheduled for trial for the week of March 13. Thus, three weeks <br /> of this short time span are effectively eliminated. <br /> You have provided some dates for Robert and Diane Delaney <br /> for the week of February 20 and for the last two weeks of March. <br /> You also mention that John. ,Reeves may only be available for <br /> deposition the last two weeks of March. Considering the <br /> scheduling of the motions hearing and the need to complete <br /> discovery and file a disclosure certificate by March 30, there <br /> may not be sufficient time to complete discovery given the <br /> defendants' and Joel's schedules. <br /> In addition, you will be receiving a separate letter by fax <br /> today which concerns the adequacy of the defendants' response to <br /> the plaintiff's written discovery request. The depositions of <br /> the defendants in part depend on the defendants' response to this <br /> letter. However, in an effort to meet the discovery deadline in <br /> conjunction with the defendantsr and Joel's schedules, I will at <br /> this point set the deposition of Diane Delaney for February 24, <br /> 1995; John Reeves for March 20, 1995; and Robert Delaney for <br /> March 21, 1995. As stated above, the defendants' depositions are <br /> subject to the outcome of the defendants' response to the <br /> Plaintiff's letter concerning the written discovery. <br />