HUSCH BLACKWELL - ESPN · Husch Blackwell stating that Request Nos. 13, 14, 17-19, 20, 22, and 23 in the June 241h PRR will be responded to, but additional time is needed to respond

HUSCH BLACKWELL

Steven Martin Aaron Partner

1620 Dodge Street, Suite 2100 Omaha, NE 68102 Telephone: 402.964.5000 Fax: 402.964.5050 [email protected]

June 24, 2011

VIA U.S. MAIL & E-M_AIL

Dr. John Christensen Office of the Chancellor UniversitS, of Nebraska at Omaha 202 EAB Omaha, NE 68182 [email protected]

Trey Alberts Athletic Director University of Nebraska at Omaha 202 FH Omaha, NE 68182 [email protected]

Dear Dr. Christensen and Mr. Alberts:

Our firm, has been retained by student-athletes to review and evaluate their legal rights and available remedies related to the University of Nebraska at Omaha's ("UNO") termination of the football and wrestling programs, and to pursue litigation as needed and warranted. As you have been aware since at least March 2011, litigation by student-athletes against UNO is imminent. Accordingly, the university and its agents or representatives have had and continue to have a duty to protebt and preserve all potentially relevant evidence, including electronic and hard copy files. Potentially relevant evidence includes, but is not limited to, any and all information, things, communications and documents related to: the termination of football and wrestling programs; UNO's transition to a different conference or to Division I; athletic budgets, shortfalls, audits, and financial reports; agreements and communications with student-athletes and recruits; Mr. Albert's employment; the construction of a hockey arena; and all documents and categories of documents sought by our finn, the Omaha World :Herald, ESPN, or any other third party in public records requests to the university.

Failure to preserve such information can result in sanctions, adverse inferences at trial, and/or entry of judgment. This matter requires preservation of documents, things, and all

EXHIBIT A .

Husch Blackwell LLP OMA-326575-1

HUSCH BLACKWELL Christensen Alberts

, June 24, 2011 Page 2

electronic information from your computer systems, removable electronic media, and other locations. Document formats that must be preserved include, but are not limited to, hardcopy documents, electronic files; objects, e-mail and other electronic communication, such as text messages, instant messaging, and social networking messages and posts, word processing documents, spreadsheets, databases, calendars, telephone logs, voicemail, contact manager information, and other forms of digital data that may contain potentially relevant information.

If the university's electronic information system routinely alters, overwrites, or deletes the types of data that may be relevant to this matter, you must suspend these actions to preserve this data.. All agents and representatives of the university who potentially possess relevant information or evidence must be advised of their duty to preserve. evidence. Information that has been previously deleted or removed should be located and restored, and all potential sources of back-up or retention of such information must be protected. Failure to explore data servers for potential back-up or duplicate copies of documents and comimmications that were previously deleted, constitutes another violation of your preservation duty (with the initial deletion being the first violation).

Thonlc you for your cooperation regarding this essential obligation.

Very truly yours,

)effia(J/u ,4(iej


SMA

OMA-326575-I Husch Blackwell !LP

HUSCH BLACKWELL

Hemy L. Wiedrich Attorney


November 7, 2011

VIA U.S. MAIL & E-MAIL

John Wiltse Deputy General Counsel University of Nebraska P.O. Box. 830745 Lincoln, NE 68583-0745 [email protected]

. Re: Public Records Request

Dear Mr. Wiltse:

As you are aware, we have not been satisfied with the University's' position with regard to our public records request, which was initially presented on. June 24, 2011 and subsequently limited on September 2, 2011. In our estimation, the University has presented inflated cosi estimations to respond to our requests,.and has over complicated what is a rather straight forward process. In. doing so, the University has taken a poSition that essentially makes public records unavailable to the public. - Given the source of the University's funds and the purpose of its mission as a public institution of higher education, this is a disturbing trend.

In light of our disagreement, and in light of the fact that the Attorney General's Office has not pressed this issue with you, we have decided to withdraw our previous public records request and submit a new request. Our withdrawal of the previous reqUest should not be construed in any manner as a release of the litigation hold notice that was sent in June. The University's duty (and the duty of its agents and employees) to preserve documents related to and relevant to its decision to terminate the footb4 and wrestling programs continues.

The new public records request, set forth below, is more limited in breadth and time. It has been crafted such that gathering responsive documents will not be difficult, and should be far.. less costly: We expect the University's cost estimate to reflect that.

Pursuant to the Nebraska Public Records Act, Neb. Rev. Stat. § 84-712 et seq., we request copies of the following documents and public records:

EXHIBIT Husch Blackwell LLP OMA-332321-3

HUSCH BLACKWELL Wiltse . November 7, 2011 Page 2

1. All e-mails and letters between John Christensen and Trey Alberts from June 1, 2010 to April, 30 2011.

2. All e-mails and letters from John Christensen to Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J.B. Milliken, and/or Clary Castner, from June 1, 2010 to April 30, 2011. .

3. All e-mails and letters received by John Christensen from Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J.B. Milliken, and/or Clary Castner, from June 1, 2010 to April 30, 2011.

4. All e-mails and letters from Trev Alberts to Ken Stinson, Walter Scott, Jim Young, Dana Bradford, LB. Milliken, and/or Clarence Castner, from June 1, 2010 to April 30, 2011.

5. All e-mails and letters received. by Trey Alberts from Ken Stinson, Walter Scott,. Jim Young, Dana Bradford, .T.B. Milliken, and/or Clarence Castner, froin June 1, 2010 to April 30, 2011.

We agree. that the. University's search for responsive electronic files may be limited . to a search of the University's e-mail server(s) and the desktop or laptoP computers issued by the University to Mr. Christensen and Mr. Alberts (if users are permitted to save e-mails and/or documents to local computers). Although electronic files stored in . other locations must be preserved, subject to the litigation hold notice, they are not the subject of this request.

We request that el,ectronic files be produced in their native format, on a hard drive. Production of electronically stored documents in PDF format is not acceptable. Husch Blackwell will pay for reasonable photocopying costs and rdasonabIe costs of retrieving and producing electronic files. If such costs will exceed fifty dollars, consistent with the statute, we ask that a reasonable, itemized cost estimate be provided prior to undertaking such efforts.

In accordance with Neb. Rev. Stat. § 84-712(4), I request that copies of the above documents be provided to me within four (4) business days of your receipt of this request. In the event the University claims a legal basis for the denial of any of the above requests, please set forth the legal basis of such denial in your response, as required by Neb, Rev. Stat..§ 84-712(4), 84-712.04.

If you have any questions or need mord information in order to expedite this request, please call me at (402) 964-5142. I look forward to Your response.

Very truly yours,

D_CA,0 4- .0 - Henry L. Wiedrich

OMA-332321-3 Husch Blackwell LLP

HUSCH BLACKWELL • Wiltse

November 7, 2011 Page 3

1-1.LW

cc: Steven Martin Aaron


HUSCH BLACKWELL

TIMELINE OF CORRESPONDENCE WITH UNO REGARDING PUBLIC RECORDS REQUESTS

1. Initial public records request by Husch Blackwell to UNO, containing requests for 25 categories of documents ("June 24 th PRR"). (June 24, 2011)

2. Letter from John Wiltse, General Counsel for the University of Nebraska, to Husch Blackwell stating that Request Nos. 13, 14, 17-19, 20, 22, and 23 in the June 241h PRR will be responded to, but additional time is needed to respond on the other categories. (June 30, 2011)

3. E-mail from Steve Aaron of Husch Blackwell to Wiltse agreeing to provide payment and deposit for Request Nos. 13, 14, 17-19, 20, 22, and 23, and looking forward to response to other categories. (July 5, 2011)

4. Letter from Wiltse to Husch Blackwell stating that an advanced deposit of $9,000 would be needed to respond to Request Nos. 1-12, 15, 16, 21, and 24-25 of the June 24th PRR. (July 8, 2011)

5. Letter from Lynn A. Stephenson to Husch Blackwell confirming receipt of payment of $497.50 for documents provided in response to Request Nos. 13, 14, 17-19, 20, 22, and 23. (July 21, 2011)

6. Letter from Wiltse to Dale Corner, Assistant Attorney General, regarding Husch Blackwell's June 24th PRR and the advanced deposit requested by UNO. (August 8, 2011)

7. Letter from Henry Wiedrich of Husch Blackwell to Wiltse limiting outstanding requests in June 24th PRR to just four categories of documents ("September 2 nd PRR"). (September 2, 2011)

8. Letter from Wiltse to Wiedrich requesting an advanced deposit of $6,000 before proceeding with the September 2 thl PRR and insisting upon the use of search terms. (September 9, 2011)

9. In response to the inflated costs presented by UNO and their insistence upon using search terms, a letter by Wiedrich to Wiltse withdrawing the June 24 th PRR and the September 2nd PRR and instituting a new public records request, limited to just 5 categories of documents, limited hardware search, and limited senders and receivers ("November 7 th PRR"). (November 7, 2011)

10. Letter from Wiltse to Wiedrich stating that the cost of the search in responding to the November 7th PRR would be $1,500, requesting an advanced deposit of $1,250, and stating that search terms would be used to locate responsive documents. (November 11, 2011)

1 Husch Blackwell LLP

HUSCH BLACKWELL

11. Letter from Wiedrich to Wiltse stating that no search terms should be used, but the $1,250 advanced deposit would be paid. (November 21, 2011)

12. Letter from Wiltse to Wiedrich stating that search terms must be used and that the cost estimate of November 11, 2011 letter was only valid with the use of search terms. (November 22, 2011)

13. Letter from Wiedrich to Wiltse contesting the need for search terms and any claim that the requests are not sufficiently particular in the description of the records sought. (November 23, 2011)

14. Letter from Wiltse to Wiedrich refusing to provide a cost estimate on the November 7th PRR. (December 1, 2011)

15. Letter from Wiedrich to Wiltse again requesting a cost estimate on the November 7th PRR or a formal denial of the PRR. (December 15, 2011)

16. Letter from Wiltse to Wiedrich denying the November 7 th PRR. (December 21, 2011)

17. E-mail from Wiedrich to Wiltse requesting all letters of denial of requests for records for the last 3 years (December 21 st PRR). (December 21, 2011)

18. Letter from Wiltse to Wiedrich acknowledging December 21 st PRR. (January 4, 2012)

19. Letter from Wiltse to Wiedrich requesting payment of $50.38 for responses to the December 21 st PRR (file of denial letters). (January 12, 2012)

OMA-340539-1

11-IUSCH BLACKWELL

ITEMIZATION OF UNO'S RESPONSES TO PUBLIC RECORDS REQUESTS

June 24th Public Records Request'

Requests Granted by UNO: Request Nos. 13, 14, 17-19, 20, 22, and 23

Requests Denied by UNO: Request Nos. 1-12, 15, 16, 21, and 24-25

September 2" Public Records Request 2

Requests Granted by UNO: None.

Requests Denied by UNO: Request Nos. 1-4

November 7 th Public Records Request3

Requests Granted by UNO: None.

Requests Denied by UNO: Request Nos. 1-5

Attached as Exhibit 1. 2 Attached as Exhibit 2. 3 Attached as Exhibit 3.

OMA-340587-1

EXHIB I T

II

HUSCH BLACKWELL


1620 Dodge Street Suite 2100 Omaha, NE 68102 Telephone: 402.964.5000 Fax: 402.964.5050 [email protected]

June 24, 2011


Dr. John Christensen Office of the Chancellor University of Nebraska at Omaha 202 EAB Omaha, NE 68182 johnchristensenmail.unomaha.edu

Trey Alberts Athletic Director University of Nebraska at Omaha 202 FH Omaha, NE 68182 [email protected]_edu

Dear Dr. Christensen and Mr. Alberts:

Pursuant to the Nebraska Public Records Act, Neb. Rev. Stat. § 84-712 et seq., I write to • request copies of the following documents and public records:

1. All communications, including e-mails and text messages, by or between agents or representatives of the University of Nebraska at Omaha ("UNO") regarding the potential or actual elimination of the football or wrestling programs, from April 2009 to the present

2. All communications, including e-mails and text messages, by or between agents or representatives of UNO regarding athletic budget projections and athletic budget shoi Lfalls, from April 2009 to the present.

3. All communications, including e-mails and text messages, by or between agents or representatives of UNO regarding joining the Summit League.


FIUSCH BLACKWELL Christensen Alberts June 24, 2011 Page 2

4. All communications, including e-mails and text messages, by or between agents or representatives of UNO and student-athletes regarding the potential or actual elimination of the football or wrestling programs, from April 2009 to the present.

5. All communications, including e-mails and text messages, by or between agents or representatives of UNO and UNO alumni, supporters, or boosters regarding the potential or actual elhnination of the football or wrestling programs, from April 2009 to the present. •

6. All communications, including e-mails and text messages, by or between agents or representatives of UNO and agents or representatives of the Omaha World Herald regarding the potential or actual elimination of the football or wrestling programs, from April 2009 to the present.

7. All communications, including e-mails and text messages, by or between agents or representatives of UNO and agents or representatives of the University of Nebraska at Lincoln, including its athletic department, regarding the potential or actual elimination of the football or wrestling programs, from April 2009 to the present.

8. All communications, including e-mails and text messages, by or between agents or representatives of UNO and regents of the University of Nebraska regarding the potential or actual elimination of the football or wrestling programs, from April 2009 to the present.

9. All communications, including e-mails and text messages, by or between agents or representatives of UNO and auditors and/or accountants regarding the potential or actual elimination of the football or wrestling programs, athletic budget projections, or athletic budget shortfalls, from April 2009 to the present.

10. All communications, including e-mails and text messages, by or between agents or representatives of UNO and agents or representatives of the Summit League regarding UNO potentially or actually joining the Summit League.

11. All communications, including e-mails and text messages, by or between agents or representatives of UNO and agents or representatives of any Division I conference related to UNO changing conference affiliation, requests by UNO for invitation into a conference, or joining Division I, including communications with the Missouri Valley Conference, from April 2009 to the present.

12. All communications, including e-mails and text messages, by or between agents or representatives of UNO and potential football recruits in 2010 and 2011.

OMA-326394-1 Husch Bla .ckwell LLP

HUSCH BLACKWELL Christensen Alberts June 24, 2011 Page 3

13. All Financial Aid Agreements or other scholarship agreements for student-athletes participating in wrestling or football at UNO in 2010 and 2011.

14. All audits and financial reports of UNO's athletic department from 2009 to the present.

15. All documents prepared by UNO agents or representatives regarding or discussing the potential or actual elimination of the football or wrestling programs.

16. All documents prepared by UNO agents or representatives regarding or discussing UNO' s potential for joining the Summit League.

17. All public record requests or freedom of information requests received by UNO which sought documents related to the elimination of the football or wrestling programs, including requests submitted by the Omaha World-Herald and ESPN.

18. All documents produced in response to public record requests or freedom of information requests received by UNO which sought documents related to the elimination of the football or wrestling programs, including the documents produced to the Omaha World-Herald and ESPN.

19. All record retention policies of UNO and UNO' s athletic department.

20. All bids, proposals, contracts, or other documents by or between UNO and any public relations firms related to the elimination of the football or wrestling programs.

21. All communications, including e-mails and text messages, by or between agents or representatives of UNO and agents or representatives of any public relations firm hired or retained with regard to the elimination of the football or wrestling programs.

22. All communications, bids, proposals, contracts, or other documents by or between UNO and any other party regarding the construction of a hockey arena for UNO's hockey team, from April 2009 to the present.

23. All contracts of employment between UNO and Trey Alberts and any other documents evidencing the employment relationship between UNO and • Trey Alberts.

24. All communications, including e-mails and text messages, by or between agents or representatives of UNO and Trey Alberts regarding the expectations of his position, the purpose of his hiring, or UNO' s transition to Division I.


• Christensen Alberts June 24, 2011 Page 4

HUSCH BLACKWELL

25. All Board of Regents reports, documents, or communications, including e-mails and text messages, discussing the elimination of the football or wrestling programs at UNO, from 2001 until the present.

All documents should be produced in their native format, if they are stored electronically. Copies of documents stored as paper files may be copied and the copies may be produced. Husch Blackwell will pay for reasonable photocopying costs and for reasonable costs of placing the electronic copies, in their native format, on a hard drive. Husch Blackwell will also bear the reasonable costs of a hard drive or other medium to hold the native electronic copies.

In accordance with Neb. Rev. Stat. § 84-712(4), I request that copies of the above documents be provided to me within four (4) business days of your receipt of this request. In the event the University claims a legal basis for the denial of any of the above requests, please set forth the legal basis of such denial in your response, as required by Neb. Rev. Stat. §§ 84- 712(4), 84-712.04.

If you have any questions or need more information in order to expedite this request, please call me at (402) 964-5000. I look forward to your response.

Very truly yours,


SMA

Husch Blackwell LLP OMA-326394-1

';',cH J 311

HUSCH BLACKWELL

Henry L. Wiedrich Attorney

1620 Dodge Street, Suite 2100 Omaha, NE 68102 Telephone: 402.964.5142 Fax: 402.964.5050 henry.wiedric1i@husebb1ackwe1Loom

September 2, 2011


John Wiltse Deputy General Counsel University of Nebraska P.O. Box 830745

Lincoln, NE 68583-0745 j wiltse@nebraska. edu

Re: Public Records Request, dated June 24, 2011

Dear Mr. Wiltse:

While we fundamentally disagree with the position you have taken in your August 12, 2011 response to the Nebra&ka Attorney General's Office with regards to our Public Records Request of June 24, 2011, we have decided it is expedient to simply limit our requests at this time. Although all of the documents requested will be relevant to the litigation by student athletes adversely affected by UN0's conduct, such documents can be sought during discovery. Accordingly, we hereby limit OUT request to the following categories:

1. All corresPondence, e-mails, and text messages in Trey Alberts' posSession regarding the potential or actual elimination of the football or wrestling programs, dated, created, or received from. April 2009 to the present

2. All . correspondence, e-mails, and text messages in Trev Alberts' possession regarding UM} potentially or actually joining the Summit League.

3. All correspondence, e-mails, and text messages in John Christensen's possession regarding the potential or actual elimination of the football or wrestling programs, dated, created, or received from April 2009 to the present.

4. All correspondence, e-mails, and text messages in John Christensen's possession regarding UNO potentially or actually joining the Summit League.

In accordance with Neb. Rev. Stat § 84-712(4), I request that copies of the above documents be provided to me within four (4) business days of your receipt of this request In the

0MA-329500-1 Hitsch Blackwell LLP

HUSCH BLACKWELL Vase September 2, 2011 Page 2

event the University claims a legal basis for the denial of any of the above requests, please set forth the legal basis of such denial in your response, as required by Neb. Rev. Stat. § 84-712(4), 84-712.44.

If you have any questions or need more infoimation in order to expedite this request, please call me at (402) 964-5000, I look forward to your response.

Very truly yours,

Henry L. Wiedrich Attorney

HLW

co: Steven Martin Aarbn

OlvfA-329500-I Husch Blackwell LLP

Page 1 of 1

Dolton, Joyce

From: Dolton, Joyce

Sent: Friday, September 02, 2011 4:28 PM

To: '[email protected] '

Cc: Aaron, Steven Martin; Baumert, Michaelle; Wedrich, Henry

Subject: Public Records Request, June 24; 2011

Attachments: 9 2 11 Wiltse.pdf

Please refer to the attached correspondence from H. Wiedrich.

Thank you,

Joyce A. Dolton Legal Administrative Specialist

HUSCH BLACKWELL LLP 1620 Dodge Street, Suite 2100 Omaha, NE 68102 Direct: 402.964.5219 Fax: 402.964.5050 Joyce.DoltonPhuschblackwell.com huschblackwell.com

Begin Notice from Husch Blackwell LLP

This e-mail message and all attachments, if any, may contain Confidential and privileged material and are intended only for the intended recipient. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail or by calling (816) 983-8000 and destroy the original and any copies of this e-maiL

End Notice from Husch Blackwell LLP

9/6/2011

HUSCH BLACKWELL

EXHIBIT

3

Hemy L. Wiedrich Attorney


November 7, 2011

VIA U.S. MALL & E-MAIL

John Wiltse Deputy General Counsel University of Nebraska

- P.O. Box 830745 Lincoln, NE 68583-0745 jwiltse(&,nebraska.edu

Re: Public Records Request

Dear Mr. Wiltse:

As you are aware, we have not been satisfied with the University's position with regard to our public records request, which was initially presented on June 24, 2011 and subsequently limited on September 2, 2011. In our estimation, the University has presented inflated cost estimations to respond to our requests, and has over complicated what is a rather straight forward process. In doing so, the University has taken a poSition that essentially makes public records unavailable -Lb the public. - Given the source of the University's funds and the purpose of its mission as a public institution of higher education, this is a disturbing trend.

In light of our disagreement, and in light of the fact that the Attorney General's Office has not pressed this issue with you, we have decided to withdraw our previous public records request and submit a new request. Our withdrawal of the previous reqUest should not be construed in any manner as a release of the litigation hold notice that was sent in June. The University's duty (and the duty of its agents and employees) to preserve documents related to and relevant to its decision to terminate the football and wrestling programs continues.

The new public records request, set forth below, is more limited in breadth and time. It has been crafted such that gathering responsive documents will not be difficult, and should be far.. less costly: We expect the University's cost estimate to reflect that.

Pursuant to the Nebraska Public Records Act, Neb. Rev. Stat. § 84-712 et seq., we request copies of the following documents and public records:


HUSCH BLACKWELL Wiltse November 7, 2011 Page 2

1. All e-mails and letters between John Christensen and Trey Alberts from June 1, 2010 to April, 30 2011.

2. All e-mails and letters from John Christensen to Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J.B. Milliken, and/or Clary Castner, from June 1, 2010 to April 30, 2011.

3. All e-mails and letters received by John Christensen from Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J B Milliken, and/or Clary Castner, from June 1, 2010 to April 30, 2011.

4. All e-mails and letters from Trey Alberts to Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J.B. Milliken, and/or Clarence Castner, from June 1, 2010 to April 30, 2011.

5. All e-mails and letters received by Trey Alberts from Ken Stinson, Walter Scott, Jim Young, Dana Bradford, J.B. Milliken, and/or Clarence Castner, from June 1, 2010 to April 30, 2011.

We agree that the University's search for responsive electronic files may be limited .to a search of the University's e-mail server(s) and the desktop or laptop . computers issued by the University to Mr. Christensen and Mr. Alberts (if users are permitted to save e-mails and/or documents to local computers). Although electronic files stored in other locations must be preserved, subject to the litigation hold notice, they are not the subject of this request.

We request that electronic files be produced in their native format, on. a hard drive. Production of electronically stored documents in PDF format is not acceptable. Husch Blackwell will pay for reasonable photocopying costs and reasonable costs of retrieving and producing electronic files. If such costs will exceed fifty dollars, consistent with the statute, we ask that a reasonable, itemized cost estimate be provided prior to undertaking such efforts.

In accordance with Neb. Rev. Stat. § 84-712(4), I request that copies of the above documents be provided to me within four (4) business days of your receipt of this request. In the event the University claims a legal basis for the denial of any of the above requests, please set forth the legal basis of such denial in your response, as required by Nap: Rev. Stat. § 84-712(4), 84-712.04.

If you have any questions or need more information in order to expedite this request, please call me at (402) 964-5142. I look forward to Your response.

Very truly yours,

Henry L. Wiedrich


1-IUSCH BLACKWELL Wiltse November 7, 2011 Page 3

HLW

cc: Steven Martin Aaron


Neby.s§10.1

OFFICE OF THE VICE PRESIDENT AND GENERAL COUNSEL

December 21, 2011

Via e-mail to: henry.wiedrichOhuschblackwell.corn steveaaronahuschblackwell.com

Mr. Henry L. Wiedrich, Esq. Husch Blackwell LLP 1620 Dodge Street, Suite 2100 Omaha, NE 68102-1504

RE: Response to your letter dated December 15, 2011

Dear Mr. Wiedrich:

You have been informed that fulfilling your request using subject terms would cost more than $50, provided with an estimate and an advance deposit amount. I have declined to fulfill your request without using subject terms, and estimated that if such a request wete fulfilled, it would cost more and take longer than the November n estimate, You have not paid an advance deposit, so work will not proceed. The University will be closed for winter break from December 26, 2011 until January 2, 2012.

If you are dissatisfied with the response you have received, you may appeal as specified in Neb. Rev. Stat. § 84-712.03 (Reissue 2008).

Very truly yours

I t -

Wiltse Deputy General Counsel

2011 1221 new PRR Hemy L. Wiedrich dale.cornerOnebraska.gov

Varner Han / 3835 Holdrege Street / P. O. Box 830745 / Lincoln, NE 68583-0745

(402) 472-1201 / FAX; (402) 472-2038 /www,nebraska.edu

Documents

HUSCH BLACKWELL - ESPN · Husch Blackwell stating that Request Nos. 13, 14, 17-19, 20, 22, and 23 in the June 241h PRR will be responded to, but additional time is needed to respond