This is an update to
my November 29, 2004, email reporting
that Magistrate Judge Edward Schlatter will
conduct a scheduling conference in the
Phelps v. Qwest EBC case on February 3,
2005. As you know, this case concerns the
legal challenge to Qwest's wholesale denial
of our request for a copy of: 1) the
pension plan "investment policy
guidelines"; and 2) the pension plan and
health care plan "investment trust proxy
voting policy." The case will proceed to
a scheduling conference where we will have
our first meeting with the Magistrate Judge
for the purpose of setting dates on
depositions and the parameters of formal
discovery requests, such as interrogatories
and document requests.
In advance of the
scheduling conference, today, I sent to
Qwest's outside counsel a formal discovery
request, 9 interrogatories and 8 separate
requests for documents. Qwest will be
required to provide a response (i.e., answer
the questions and produce the documents) 30
days after the February 3, 2005, scheduling
conference. A copy of the pending formal
discovery request is attached hereto in
Adobe PDF file format.
Curtis
Curtis L. Kennedy
Attorney-at-law
8405 E. Princeton Ave.
Denver, CO 80237-1741
Tele: 303-770-0440
Fax: 303-843-0360
CurtisLKennedy@aol.com