Exhibit B, Email, Response to Motion to Amend Judgment — Abrams v. Division of Unemployment Insurance

Summary

Exhibit B, Document 57-2 in Abrams v. Division of Unemployment Insurance, No. 1:24-cv-03390-RMR (D. Colo.), filed October 16, 2025. It is an email dated Wed, Oct 15, 2025 at 3:06 PM from Lauren Davison, Senior Assistant Attorney General in the Tort Litigation Unit of the Colorado Department of Law, to Josh Abrams, with Stephen Woolsey and Denise Munger copied, under the subject Abrams v. Div. of Unemployment - Response to Motion to Amend Judgment. The email states that State Defendants do not consent to vacating judgment or amending the Complaint and oppose filing a Third Amended Complaint. It states that judgment has entered and the case remains closed, making any attempts to amend improper unless the court grants the Rule 59(e) motion and reopens the case.

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“Exhibit B, Email, Response to Motion to Amend Judgment — Abrams v. Division of Unemployment Insurance.” Original at ecf.cod.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/exhibit-b-abrams-v-division-of-unemployment-insurance-dkt-57-2-d-colo-785a3f8f44/, SHA-256 9405de6aea0f2b62349c045ef0deb03840372575ce93c85b3d1c99f196caace1.

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Case No. 1:24-cv-03390-RMR Document 57-2 filed 10/16/25 USDC Colorado’ pg
10/15/25, 7:20 PM Gmail - Abrams v. Div. oftuREnabloyment - Response to Motion to Amend Judgment

hi Gmail Josh Abrams <abramslive@gmail.com>

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

Lauren Davison (She/Her) Wed, Oct 15, 2025
<Lauren.Davison@coag.gov> at 3:06 PM

To: Josh Abrams <abramslive@gmail.com>
Cc: "Stephen Woolsey (He/Him)" <Stephen.Woolsey@coag.gov>, Denise
Munger <Denise.Munger@coag.gov>

Mr. Abrams:

Thank you for your email. State Defendants do not consent to vacating judgment or amending your
Complaint. For the reasons stated in State Defendants’ response to your motion, Williams v. Reed is
distinguishable. State Defendants oppose filing a Third Amended Complaint. Judgment has entered and
the case remains closed, making any attempts to amend improper unless the court grants your Rule 59(e)
motion and reopens the case. We are unable to offer legal advice as to how you may cure the deficiencies
in your Amended Complaint.

Respectfully,

Lauren Davison (She/Her)

Senior Assistant Attorney General |

Tort Litigation Unit | Colorado Department of Law

Pronouns: she/her

https://mail.google.com/mail/u/0/?ik=635ca0c2b9&view=pt&search=all&permmsgid=msg-f:1846083450067724021 &simpl=msg-f:1846083450067724021

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