Sprint Communications Company LP v. Vonage Holdings Corp., et al

Filing 369

OBJECTION(S) to 349 First Supplemental EXHIBIT LIST filed by Vonage by Sprint Communications Company LP. (Attachments: # 1 Exhibit A)(Seitz, Adam)

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Sprint Communications Company LP v. Vonage Holdings Corp., et al Doc. 369 Case 2:05-cv-02433-JWL Document 369 Filed 09/10/2007 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS SPRINT COMMUNICATIONS COMPANY L.P., ) ) ) Plaintiff, ) ) v. ) ) VONAGE HOLDINGS CORP., VONAGE AMERICA, INC., ) ) ) Defendants. ) Case No. 05-2433-JWL PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P.'S OBJECTIONS TO VONAGE'S FIRST SUPPLEMENTAL EXHIBIT LIST Plaintiff files these objections to Vonage's designation of exhibits in Vonage's First Supplemental Exhibit List. Plaintiff reserves the right to object to any additional exhibits and witnesses added by Vonage. Plaintiff also reserves the right to object to exhibits that Vonage has not yet produced to Sprint. Plaintiff expressly reserves all objections under Federal Rules of Evidence 402 and 403 pursuant to Fed. R. Civ. P. 26(a)(3). Reserving its objections under Fed. R. Evid. (FRE) 402-403, as permitted by Fed. R. Civ. P. 26(a)(3), Plaintiff makes the following objections: GENERAL OBJECTIONS Plaintiff generally objects to each and every exhibit listed by Vonage to the extent addressed by a Motion in Limine filed by Plaintiff. Plaintiff also objects to each and every exhibit listed by Vonage regarding the JCS-2000 system on the grounds that such exhibit(s) are not relevant and, therefore, inadmissible under FRE 402. Finally, Plaintiff objects to each 2620981v1 Dockets.Justia.com Case 2:05-cv-02433-JWL Document 369 Filed 09/10/2007 Page 2 of 3 exhibit identified by Vonage that was not produced pursuant to discovery requests or that was identified for the first time in connection with Vonage's § 282 Notice. EXHIBITS Sprint's objections to the exhibits identified by Vonage in its First Supplemental Exhibit List are set forth in Exhibit A. Sprint reserves the right to object to any exhibits identified by Vonage at a later date. Dated: September 10, 2007 Respectfully Submitted, _/s/ Adam P. Seitz______________________ B. Trent Webb, KS Bar No. 15965 Eric A. Buresh, KS Bar. No. 19895 Adam P. Seitz, KS Bar No. 21059 SHOOK HARDY & BACON L.L.P. 2555 Grand Blvd. Kansas City, Missouri 64108-2613 816-474-6550 Telephone 816-421-5547 Facsimile ATTORNEYS FOR PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P. -2 2620981v1 Case 2:05-cv-02433-JWL Document 369 Filed 09/10/2007 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that on this 10th day of September, 2007, a copy of PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P.'S OBJECTIONS TO VONAGE'S FIRST SUPPLEMENTAL EXHIBIT LIST was e-filed with the Court, which sent notice to the following: Don R. Lolli Patrick J. Kaine Dysart Taylor Lay Cotter & McMonigle P.C. 4420 Madison Avenue Kansas City, Missouri 64111 Terrence J. Campbell Catherine Theisen Barber Emerson, L.C. 1211 Massachusetts Street P.O. Box 667 Lawrence, KS 66044 Patrick D. McPherson Patrick C. Muldoon Donald R. McPhail Barry Golob Duane Morris LLP 1667 K. Street N.W. Washington, DC 20006-1608 L. Norwood Jameson 1180 West Peachtree Street Atlanta, GA 30309 Attorneys for Defendants Vonage Holdings Corp. and Vonage America, Inc. /s/ Adam P. Seitz_________________ Attorneys for Sprint Communications Company L.P. -3 2620981v1

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