Court filing — Abrams v. Division of Unemployment Insurance (Dkt. 57-1, D. Colo.)

Summary

A printed email, Document 57-1, filed 10/16/25 in Case No. 1:24-cv-03390-RMR, Abrams v. Division of Unemployment Insurance, in the USDC Colorado. In it Joshua Abrams, the pro se plaintiff, writes to counsel for the State Defendants to confer before filing a reply to their response to his Motion to Amend Judgment (ECF No. 56) or a motion for leave to file a Third Amended Complaint. He states that the Court dismissed the case on September 2, 2025 and that he filed a Rule 59(e) motion on September 22, 2025, citing Williams v. Reed (2025). He asks whether the State Defendants will consent to vacating the judgment and allowing amendment, or what changes might resolve their concerns, and asks for a written response.

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Case No. 1:24-cv-03390-RMR Document 57-1 __ filed 10/16/25 USDC Colorado’ pg
10/15/25, 7:18 PM Gmail - Abrams v. Div. oftuRsraloyment - Response to Motion to Amend Judgment

hi Gmail Josh Abrams <abramslive@gmail.com>

Abrams v. Div. of Unemployment - Response to
Motion to Amend Judgment

Josh Abrams <abramslive@gmail.com> Mon, Oct eran
To: "Lauren Davison (She/Her)" <Lauren.Davison@coag.gov>
Cc: "Stephen Woolsey (He/Him)" <Stephen.Woolsey@coag.gov>, Denise

Munger <Denise.Munger@coag.gov>

Thank you , I have received your objection and pointing out procedural
missteps 1 would like to now attempt to correct;

I am writing as the pro se plaintiff in the above-captioned matter to confer
in good faith pursuant to D.C.COLO.LCivR 7.1(a) before filing a reply to
the State Defendants’ Response to my Motion to Amend Judgment (ECF
No. 56) and/or a motion for leave to file a Third Amended Complaint.

As you know, the Court dismissed the case on September 2, 2025 (ECF
Nos. 50, 51), and I filed a Rule 59(e) motion on September 22, 2025 (ECF
No. 54), seeking vacatur based on clear legal errors, manifest injustice,
and the applicability of Williams v. Reed (2025). Your response opposes
this and my request for leave to amend. To potentially resolve or narrow
these disputes without further litigation:

1. Would the State Defendants consent to vacating the judgment and
allowing amendment, given Williams v. Reed's holding on federal
jurisdiction over systemic UI due-process violations where state
remedies are deficient or illusory?

2. Alternatively, do you oppose a Third Amended Complaint that would
further cure alleged defects (e.g., clarifying prospective relief under Ex
parte Young, limiting §504 damages to deliberate indifference,
withdrawing any retrospective claims, and emphasizing futility of
state exhaustion due to absent notices/appealable routes for
underpayment and ADA issues)?

https://mail.google.com/mail/u/0/?ik=635ca0c2b9&view=pt&search=all&permmsgid=msg-a:r1 753334496874576860&simpl=msg-a:r1 75333449687457... 1/2
Case No. 1:24-cv-03390-RMR Document 57-1 __ filed 10/16/25 USDC Colorado’ pg
10/15/25, 7:18 PM Gmail - Abrams v. Div. o2UREna@loyment - Response to Motion to Amend Judgment

3. If opposed, what specific changes or concessions might resolve your
concerns regarding exhaustion, immunity, and futility?

I am available for a phone call to discuss your lingering questions or
concerns but would appreciate a written response. Please let me know
your availability or provide your position in writing. If I do not hear back,
I will note in my certificate of conferral that I made this good-faith effort
but received no response.

Thank you for your attention.
Sincerely,

Joshua Abrams

Pro Se Plaintiff

[Quoted text hidden]

https://mail.google.com/mail/u/0/?ik=635ca0c2b9&view=pt&search=all&permmsgid=msg-a:r1 753334496874576860&simpl=msg-a:r1 75333449687457... 2/2


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gov.uscourts.cod.239393.57.1.pdf

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