From: Sabey, Mark L.

Sent: Tuesday, May 23, 2023 5:02 PM

To: mike@cpmht.com

Cc: Sebastiani, Crystal J.; McManus, Lindsay K.

Subject: Waiver of Service

Attachments: BACB v. Moates, et al.msg; 23-CV-00194 Case Docket.pdf; 2023-03-10 (1) Complaint.pdf; 2023-03-13 

(2) Summons - Moates.pdf; 2023-05-23 [15] ROS - Moates on 05.22.23.pdf; 2023-03-13 (4) Summons

- GIBPE.pdf; 2023-05-23 [16] ROS - GIBPE on 05.22.23.pdf; 2023-05-23 [17] ROS - GIBPE on

05.19.23.pdf; MagistrateConsentForm.pdf; Waiver of Service - Moates - 4869-5652-9497 v1.pdf

Mr. Moates,

For your convenience, attached is the following:

1. Case Docket

2. Complaint

3. Summons to Moates

4. Summons to GIBPE

5. Affidavit of Service upon GIBPE on 05/19/23

6. Affidavit of Service upon GIBPE on 05/22/23

7. Affidavit of Service upon Moates on 05/22/23

8. Magistrate Consent Form

9. Copy of email sent to mike@cpmht.com on 04/06/23

10. Waiver of Service

We have filed these affidavits of service with the court, and we consider service to be complete.  In your email

yesterday, you admitted that you received and looked at the packet delivered by drop service, but you

disputed that service was adequate for a variety of reasons. No need to argue about that, however, because

you agreed to waive service upon arrival if we provided the documents to you by first‐class mail or other

reliable means. Since we have been corresponding back and forth using this email address, this email is a

reliable means to provide you the attached documents. Therefore, I prepared a simple acknowledgment of

receipt and waiver of service for your signature. Please sign the waiver of service as agreed and scan the

signed copy back to me.  

Thank you for your attention to this matter.  We look forward to receiving your answer to the Complaint and

moving forward with this litigation.

Sincerely,

Mark L. Sabey | Attorney 

marksabey@hallrender.com | vCard | @hallrender on Twitter 

Hall, Render, Killian, Heath & Lyman, P.C. 

DENVER D: (303) 801-3538 | C: (303) 995-5131 | F: (303) 801-3537 

This message and any attachments are confidential and are subject to the attorney-client privilege and the privilege relating to attorney-client work product. It is intended only 

for the named recipient(s) and may be exempt from disclosure under other applicable law, as well. If you are not the intended recipient(s), you are notified that any disclosure, 

copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in 

error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone 

other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege. Hall Render hereby claims all applicable privileges related 

to this information. 

Case 4:23-cv-00194-ALM Document 42-9 Filed 08/24/23 Page 1 of 2 PageID #: 369
From: Sebastiani, Crystal J.

Sent: Thursday, April 6, 2023 3:36 PM

To: mike@cpmht.com

Subject: BACB v. Moates, et al. - New Lawsuit

Attachments: Complaint.pdf; Summons - Michael Moates.pdf; Summons - The Global Institute.pdf; Waiver of 

Service - Moates.pdf; Waiver of Service - The Global Institute.pdf

Good Afternoon Mr. Moates,

As you may know, we have refiled the BACB’s lawsuit in Texas.  We have attempted service a couple of times

and have been unable to catch you at home.  You were gracious enough to waive service when this matter

was filed in Colorado.  Would you be willing to waive service once again to avoid incurring additional costs

with a process server?   

I have attached the following for your review:

 Complaint with exhibits

 Summons to Michael Moates

 Summons to The Global Institute

 Waiver of Michael Moates

 Waiver of The Global Institute

If you are willing to waive service, please fill out and sign the Waivers for yourself as an individual and on

behalf of The Global Institute, and return to me at your earliest convenience.   

Thank you for your anticipated cooperation.  I look forward to hearing from you.  

Crystal J. Sebastiani | Paralegal 

csebastiani@hallrender.com | vCard | @hallrender on Twitter 

Hall, Render, Killian, Heath & Lyman, P.C. 

DENVER D: (303) 801-3533 | F: (303) 801-3537 

This message and any attachments are confidential and are subject to the attorney-client privilege and the privilege relating to attorney-client work product. It is intended only 

for the named recipient(s) and may be exempt from disclosure under other applicable law, as well. If you are not the intended recipient(s), you are notified that any disclosure, 

copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in 

error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone 

other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege. Hall Render hereby claims all applicable privileges related 

to this information. 

Case 4:23-cv-00194-ALM Document 42-9 Filed 08/24/23 Page 2 of 2 PageID #: 370