- Location
- Riverton, UT
We need to spread the word so the State can be effective in their suits.
From: Chris Lacombe
Sent: Friday, July 12, 2013 3:14 PM
To: j4x4jj@comcast.net
Cc: Kathleen Clarke ; Harry Souvall
Subject: Your e-mail regarding R.S. 2477 lawsuit-Jack Johnston
Dear Mr. Johnston,
This email is in response to the email that you sent to Kathleen Clarke on July 11, 2013 regarding your use of roads in the the Angel Arch area in 1973. In response to your email I called you and spoke with you for about 15-20 minutes. After discussing your specific use of roads in San Juan, Grand and Wayne County, you indicated that Utah 4 Wheel Drive Association, an organization that you are affiliated could provide witness support to these R.S. 2477 lawsuits. This office is interested in the witnesses that you can provide to this effort.
In this lawsuit, we are required to show the use of R.S. 2477 roads prior to 1976 for a period of 10 years. At the current time, we are conducting depositions of witnesses in specific counties regarding their use of roads in the 1940's-1970's. In our agreement with the United States Department of Justice, we are able to depose 200 witnesses over the next 2 years. This two year time frame has been divided into 4 six month blocks. In each block, we can depose 50 witnesses from no more than 6 counties. Currently, we are in Block 1. The Block 1 counties were depositions are currently being conducted are Washington, Sevier, Uintah, Grand and Tooele. Block 1 will end on August 31. Block 2, which we are starting to prepare for will include the following counties:
Carbon, Rich, Juab, Millard and San Juan. Block 2 will end in February 28, 2013. There will be a Block 3 and Block 4 to follow. There will be further depositions down the road after we get done with this agreement.
If your organization has witnesses who are interested in participating, they may send me an email. The witnesses for right now must be over 70 years of age and preferably 75 years of age. Witnesses tend to be more effective when their knowledge is focused to a specific area or region. Furthermore, repeated trips to an area make a witness generally more effective. Also, it is my experience that witness tend to be stronger if they testify about roads in areas closer to their homes. Their use must be before 1976 and not present day.
I may be contacted by email at clacombe@utah.gov. My office phone is 801-537-9814.
In closing I want to thank you on behalf of the State of Utah for your interest in this lawsuit and your willingness to help.
Chris Lacombe
Assistant Attorney General
From: Chris Lacombe
Sent: Friday, July 12, 2013 3:14 PM
To: j4x4jj@comcast.net
Cc: Kathleen Clarke ; Harry Souvall
Subject: Your e-mail regarding R.S. 2477 lawsuit-Jack Johnston
Dear Mr. Johnston,
This email is in response to the email that you sent to Kathleen Clarke on July 11, 2013 regarding your use of roads in the the Angel Arch area in 1973. In response to your email I called you and spoke with you for about 15-20 minutes. After discussing your specific use of roads in San Juan, Grand and Wayne County, you indicated that Utah 4 Wheel Drive Association, an organization that you are affiliated could provide witness support to these R.S. 2477 lawsuits. This office is interested in the witnesses that you can provide to this effort.
In this lawsuit, we are required to show the use of R.S. 2477 roads prior to 1976 for a period of 10 years. At the current time, we are conducting depositions of witnesses in specific counties regarding their use of roads in the 1940's-1970's. In our agreement with the United States Department of Justice, we are able to depose 200 witnesses over the next 2 years. This two year time frame has been divided into 4 six month blocks. In each block, we can depose 50 witnesses from no more than 6 counties. Currently, we are in Block 1. The Block 1 counties were depositions are currently being conducted are Washington, Sevier, Uintah, Grand and Tooele. Block 1 will end on August 31. Block 2, which we are starting to prepare for will include the following counties:
Carbon, Rich, Juab, Millard and San Juan. Block 2 will end in February 28, 2013. There will be a Block 3 and Block 4 to follow. There will be further depositions down the road after we get done with this agreement.
If your organization has witnesses who are interested in participating, they may send me an email. The witnesses for right now must be over 70 years of age and preferably 75 years of age. Witnesses tend to be more effective when their knowledge is focused to a specific area or region. Furthermore, repeated trips to an area make a witness generally more effective. Also, it is my experience that witness tend to be stronger if they testify about roads in areas closer to their homes. Their use must be before 1976 and not present day.
I may be contacted by email at clacombe@utah.gov. My office phone is 801-537-9814.
In closing I want to thank you on behalf of the State of Utah for your interest in this lawsuit and your willingness to help.
Chris Lacombe
Assistant Attorney General