Docket Number


Document Type

Reply Brief

Publication Date



Defendants7/Appellees' brief presents their case for what it truly is: a collection of shadows, shades, and inferences from the various statutes. Nowhere in their brief, and indeed nowhere in Utah law, can the Appellees point to directly applicable legal authority to sustain their argument. A plain reading of Utah law leads to the conclusion that the trial court's summary judgment should be reversed.


Original Brief Submitted to the Utah Supreme Court; digitized by the Howard W. Hunter Law Library, J. Reuben Clark Law School, Brigham Young University, Provo, Utah; machine-generated OCR, may contain errors.
Jody K. Burnett; Williams & Hunt; Stephan F. Noel; Smith, Knowles, & Hamilton; Attorneys for Appellees.
Brad C. Smith; Stevenson & Smith; Attorney for Appellants.


Public record document (some rights may be reserved).