Case No. 230905528 in the Third Judicial District Court for Salt Lake County, Utah

The following is a summary of this ongoing case and its development, followed by a table listing significant documents filed with the court, which are available to the public through the Utah Courts Xchange system. Because searching and downloading many documents through Xchange can be expensive, these documents are made available here to provide details about these cases to Bluffdale residents without the inconvenience and cost of XChange. Routine notices, certificates of service, and other inconsequential documents were left out of this analysis, but see the complete docket (as of October 6, 2025) if you’re curious about what was omitted.

NOTE THAT WITHIN THE FOLLOWING SUMMARY, THE LIST OF DOCUMENTS, AND THE DOCUMENTS THEMSELVES ARE FOUND MANY ALLEGATIONS. REMEMBER THAT THEY ARE MERELY ACCUSATIONS, REFLECTING THE POINTS OF VIEW OF THE PARTIES. THE ALLEGATIONS MAY NOT BE TRUE, AND THE DOCUMENTS MAY HAVE LITTLE OR NO EVIDENCE OR SUPPORT FOR THEM, PARTICULARLY IN THE EARLY STAGES OF THE LITIGATION.

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I. Overview of the Case

The lawsuit was brought by Jeffrey Gaston, who was a Bluffdale City Council Member at the time, against several individuals and entities following a series of alleged threats, harassment, intimidation, and a physical assault he experienced while in office and during his prospective campaign for Mayor of Bluffdale. The defendants include Jason Hall; his wife Natalie Hall (who was later elected Mayor of Bluffdale); George Schliesser; Woodcraft Mill & Cabinet, Inc. (a company associated with the Halls); and Bluffdale City itself. The core allegations are that the defendants orchestrated a campaign of harassment, including sending death threats, to force Gaston to end his mayoral run and to cause him severe emotional distress. The case has since evolved dramatically. After key parts of Gaston’s initial suit were dismissed or stayed, on May 20, 2025 the Halls filed a sweeping counterclaim, accusing Gaston and two of his political allies, Connie Pavlakis and Connie Robbins, of orchestrating a malicious scheme to frame Jason Hall for crimes he didn’t commit. The Halls allege this was done for political revenge and to sabotage Natalie Hall’s position as mayor. The lawsuit is now a dual-front conflict, with Gaston’s original claims pending against the Hall parties while the Halls pursue their own claims of defamation, emotional distress, and conspiracy against Gaston, Pavlakis, and Robbins.

II. Parties

Plaintiff / Counterclaim Defendant: Jeffrey D. Gaston (“Gaston”)

Defendants / Counterclaimants / Third-Party Plaintiffs:

• Jason Hall (“Mr. Hall”)
• Natalie Hall (“Mrs. Hall”) (in her personal capacity)

Defendants:

• Woodcraft Mill & Cabinet, Inc. (“Woodcraft”)
• George Schliesser, an employee of Woodcraft (“Schliesser”)

Third-Party Defendants:

• Connie Pavlakis (“Ms. Pavlakis”)
• Connie Robbins (“Ms. Robbins”)

Dismissed Defendants (see Document 039):

• Bluffdale City
• Natalie Hall (in her official capacity as Mayor of Bluffdale)

III. Plaintiff Gaston’s Causes of Action (against Hall Defendants & Schliesser)
Battery (against Jason Hall)

1. Civil Assault (against all remaining Defendants)
2. False Light (later dismissed with prejudice – see Document 039 and Document 079)
3. Intentional Infliction of Emotional Distress (IIED) (against all remaining Defendants)
4. Civil Conspiracy (against all remaining Defendants)

IV. Hall Defendants’ Counterclaim and Third-Party Complaint

On March 20, 2025, Jason and Natalie Hall filed a counterclaim against Gaston and a third-party complaint against Pavlakis and Robbins, alleging a coordinated effort to defame them and maliciously prosecute Mr. Hall.

• Core Allegations:
  • Gaston, Pavlakis, and Robbins conspired to prevent Natalie Hall’s mayoral election through a smear campaign, including authoring anonymous letters accusing her of favoritism and having an inappropriate relationship with the City Manager.
  • After Jason Hall sent non-threatening gag gifts and critical emails to Gaston, Gaston retaliated by fabricating a story that he had received death threats and was physically assaulted.
  • Gaston created falsified evidence, including the alleged threat letters, and knowingly provided them to police to frame Mr. Hall for crimes he did not commit. Forensic analysis allegedly shows the threat letters did not originate from Mr. Hall’s printers.
  • Pavlakis and Robbins supported Gaston’s false narrative by providing false statements to investigators, claiming to have seen Gaston bleeding from “gouges” on his arm after the alleged assault, and by organizing public protests calling for Mayor Hall’s resignation.

• Causes of Action:
  1. Intentional Infliction of Emotional Distress (IIED): Against Gaston, Pavlakis, and Robbins.
  2. Negligent Infliction of Emotional Distress (NIED): Against Gaston, Pavlakis, and Robbins.
  3. Defamation: Against Gaston, Pavlakis, and Robbins.
  4. Abuse of Process: Against Gaston only.
  5. Civil Conspiracy: Against Gaston, Pavlakis, and Robbins.

V. Significant Procedural Developments (Chronological)

1. Initial Complaint and Amendments (July – Dec. 2023): Gaston filed suit, later amending it to properly add Bluffdale City as a defendant after complying with the Governmental Immunity Act.
2. Dismissal of Bluffdale City & Mayor Hall (in her official capacity) (May 2024): The court dismissed all claims against Bluffdale City and against Mayor Hall in her official capacity.
3. Case Stay and Extension (May – Oct. 2024): The court granted a 90-day stay pending Mr. Hall’s criminal trial. This stay was later extended through December 31, 2024, after the criminal trial was continued due to the prosecutor’s unexpected death.
4. First Anti-SLAPP Motion (by Hall Parties) Denied (May 2025):
   • The Hall Parties filed a motion under Utah’s anti-SLAPP statute (UPEPA) to dismiss Gaston’s claims, arguing their communications were protected political speech.
   • The Court denied the motion, finding that several of the alleged communications could constitute “true threats” (e.g., “If you don’t you will end up dead”) and were therefore not protected speech.
   • In the same order, the Court clarified that Gaston’s False Light claim was dismissed with prejudice against Natalie Hall in both her personal and official capacities.
5. Defendants’ Joint Motion to Dismiss Gaston’s Complaint (Sept. 2024 – Ongoing):
   • The remaining defendants filed a motion to dismiss all of Gaston’s claims for failure to state a claim, arguing the allegations are conclusory and legally insufficient.
   • Gaston opposed the motion, arguing his complaint meets Utah’s liberal pleading standards.
   • The defendants replied, maintaining that the complaint improperly groups defendants together and fails to allege specific facts to support the elements of each tort. This motion appears to be pending.
6. Counterclaim and Third-Party Complaint Filed (May 2025): The Hall Defendants filed their Counterclaim against Gaston and a Third-Party Complaint against Pavlakis and Robbins.
7. Second Anti-SLAPP Motion (by Pavlakis and Robbins) (Sept. 2025 – Ongoing):
   • Third-Party Defendants Pavlakis and Robbins filed their own Special Motion for Expedited Relief under UPEPA, seeking dismissal of the claims against them. They argue the Halls’ claims are a SLAPP suit intended to chill their political participation and that their statements (e.g., letters to the city council, statements to police) are protected speech concerning a matter of public concern.
   • The Hall Parties filed an opposition on October 6, 2025, arguing the motion is untimely and that the alleged conduct—defamation with actual malice and fabricating evidence to frame someone for a crime—is not protected speech. This motion is now pending before the court.
8. Initial Disclosures Filed (Sept. 2025): The Hall Defendants filed their initial disclosures, listing potential witnesses who may testify regarding the alleged assault, the “smear letters,” and the veracity of the claims on both sides. Witnesses include former Bluffdale Mayor Derk Timothy and City Manager Mark Reid. The disclosures also outline their claim for damages, including attorney fees from the criminal case and harm to their reputations.

Case History #	Document Title	Filing Date	Summary	Key Developments
001	Complaint	July 26, 2023	This document initiated the lawsuit. Jeff Gaston sued defendants for the following causes of action: 1. Battery (against Defendant Jason Hall only), which Gaston alleged occurred at a confrontation at Old West Days in August of 2021. 2. Civil assault (all defendants, except Bluffdale City*), based on the Old West Days confrontation (on the part of Defendant Jason Hall) and for creation and delivery of threatening communications (on the part of the other defendants). *Bluffdale City excluded from this cause of action in Second Amended Complaint. 3. False Light (against Natalie Hall and Bluffdale City*) for public comments Natalie Hall is alleged to have made during a Bluffdale City Council meeting on July 27, 2022, denying that Jason Hall attacked Gaston at Old West Days and stating that Gaston’s allegations were fabricated. “False Light” is a tort recognized by Utah courts for publicizing information about a person that places them in a false light if it would be highly offensive to a reasonable person and the publisher knew the information was false or acted with reckless disregard for its truthfulness. *Bluffdale City added in Second Amended Complaint. 4. Intentional infliction of emotional distress (all defendants), based on the allegations including “harassment and intimidation of Gaston, portraying Gaston in a false light, committing battery against Gaston, and assaulting Gaston, including through the communication of numerous death threats directed to Gaston at both his public office as well as his home.” (Many of the alleged offenses form the basis for the other causes of action.) 5. Civil conspiracy (all defendants), also based on the same allegations, with this action accusing the defendants of acting in concert, with a common objective to cause injury to Gaston.	This initiated this civil case.
003	First Amended Complaint	July 27, 2023	Original complaint amended to remove Bluffdale City as a defendant. The caption of the original complaint inadvertently included Bluffdale City as a party. This was done “out of an abundance of caution” because the statutory 60-day response period required under the Governmental Immunity Act (following a Notice of Claim) had not yet expired.
011	Second Amended Complaint	December 11, 2023	Added Bluffdale City back as a defendant, added allegations supporting claims against Bluffdale City, added new allegations, updated many existing allegations, and updated causes of action, including defendants to which some causes of action would apply.	This updated version of the complaint is the basis for all subsequent activities in this lawsuit.
017	Defendant Bluffdale’s Motion to Dismiss	January 31, 2024	Bluffdale and Mayor Hall (in her capacity as mayor) asked the court to dismiss the claims against the city and the mayor, arguing that the city and the mayor (in her capacity as mayor) are immune from liability for intentional torts under Utah law. This affected the third, fourth, and fifth causes of action, to the extent they applied to the city and the mayor.
019	Defendants’ Motion to Stay Case Pending Resolution of Related Criminal Proceedings	February 7, 2024	Defendants Jason Hall, Natalie Hall, and Woodcraft Mill & Cabinet asked the court to pause, or “stay” this case due to the ongoing criminal case against Jason Hall (State of Utah v. Jason Christopher Hall, Case No: 221906445), arguing that this case is based on the same series of events cited by the State of Utah in its case against Jason Hall and that Jason Hall would suffer negative consequences in defending himself in the criminal case if forced to participate in discovery and other activities related to this civil case.
021	Defendant Bluffdale’s Motion to Dismiss	February 14, 2024	This is basically an updated version of the January 31 motion filed by Bluffdale City and Mayor Hall to dismiss the claims against the city and Mayor Hall. It adds an additional basis for dismissal. The motion presents two primary arguments: Lack of Subject Matter Jurisdiction over Mayor Hall: It argues the court lacks jurisdiction over claims against Mayor Hall because Gaston’s Notice of Claim filed under the Utah Governmental Immunity Act (UGIA) failed to specifically name her as an employee against whom a claim was being pursued, instead stating it was a “Notice of Claim against Bluffdale”. Governmental Immunity for Bluffdale City: It argues that all tort claims against the City (false light, intentional infliction of emotional distress, and civil conspiracy) must be dismissed because the UGIA does not waive immunity for torts based on intentional conduct, only for those based on negligent conduct. The court agreed with these arguments and dismissed the case for both Bluffdale parties.
024	Plaintiff’s Memorandum in Opposition to Defendants’ Motion to Stay Case	February 22, 2024	This is Gaston’s response to the Hall defendants’ February 7, 2024 motion asking the court to stay this case until the criminal case is resolved. Gaston argues that only one defendant is affected and isn’t entitled to a stay, and that Gaston will suffer prejudice in this case due to the delay, citing allegations that defendants destroyed or attempted to destroy evidence relating to this case and also listing several cancellations or delays by defendants in this case’s proceedings.
026	Defendants’ Memorandum in Support of Motion to Stay Case	March 7, 2024	This is the reply of the Hall defendants (Jason Hall, Natalie Hall, and Woodcraft) on their request for the court to stay the case during the criminal case against Jason Hall. Among other things, they argue that the requested stay is relatively brief (given the schedule of the criminal case that existed at the time of this memorandum) and that Gaston himself has not pursued this case expeditiously.
028	Plaintiff’s Memorandum in Opposition to Defendants’ Motion to Stay Case	March 14, 2024	This is Gaston’s rebuttal to the defendants’ March 7, 2024 Memorandum. The court was ultimately unpersuaded and granted both the initial stay and the extension.
030	Plaintiff’s Memorandum in Opposition to Defendants’ Motion to Dismiss with Prejudice	March 14, 2024	Gaston agreed to dismiss Bluffdale City from the case, but not the mayor. Gaston stipulated to dismissing Bluffdale City but argued the case against Mayor Hall should proceed because his claim notice was sufficient and some of her alleged actions were done in her personal capacity, not as mayor.
032	Defendant Bluffdale’s Reply Memorandum in Support of Motion to Dismiss	April 1, 2024	This is Bluffdale’s reply to Gaston. Bluffdale and Mayor Hall argued that the law requires “strict compliance” and that simply mentioning the mayor’s name in a claim notice is not enough; the notice must explicitly state a claim is being pursued against that employee.
039	Order Granting Defendant Bluffdale’s Motion to Dismiss with Prejudice	May 13, 2024	The Judge removed Bluffdale City and Mayor Hall (as mayor) from the lawsuit. The court officially dismissed all claims against Bluffdale City and all claims against Mayor Hall in her official capacity. The dismissal was “with prejudice,” meaning those claims cannot be re-filed.	This was a pivotal development, removing the governmental defendants and narrowing the case to a dispute between private citizens.
043	Order Granting Motion to Stay Case	May 16, 2024	The judge officially paused the lawsuit. The court ordered a 90-day stay until August 11, 2024.	The lawsuit was frozen to allow the parallel criminal case against Jason Hall to proceed first.
049	Defendant Hall’s Motion to Extend Stay	August 12, 2024	The Hall Defendants filed this motion seeking to extend the stay because the June 2024 criminal trial was continued after the lead prosecutor, Steven Wuthrich, died unexpectedly the day before the trial was to begin. The criminal trial was rescheduled for October 2024. They argued that the continuance was due to a tragic, unforeseeable event beyond anyone’s control and that the factors justifying the initial stay (protecting Mr. Hall’s Fifth Amendment rights) still applied.
051	Plaintiff’s Memorandum in Opposition to Motion to Extend Stay	August 26, 2024	Gaston opposed the extension, arguing that the court’s original order had already explicitly contemplated a continuance and dictated that the stay would expire regardless of the reason. He claimed further delay would prejudice his ability to pursue his claims.
053	Defendant Hall’s Reply in Support of Motion to Extend Stay	September 3, 2024	The Hall defendants continue to argue that the extension is justified because the criminal trial’s postponement was due to the unforeseen and tragic death of the lead prosecutor on the eve of trial, a circumstance beyond anyone’s control. Also, forcing Jason Hall to participate in discovery for the civil case before his rescheduled criminal trial would cause him serious prejudice by forcing him to choose between his constitutional right against self-incrimination and defending himself in this lawsuit.
054	Request to Submit for Decision – Motion to Extend Stay	September 3, 2024	Hall formally asked court to rule on the motion to extend stay.
058	Defendants’ Joint Motion to Dismiss Second Amended Complaint	September 5, 2024	All remaining defendants (the Halls, Schliesser, and Woodcraft) filed a joint motion to dismiss the entire Second Amended Complaint for failure to state a claim. Their key arguments for dismissal of each count are: Battery: The complaint fails to allege facts showing Mr. Hall had the required intent to make harmful or offensive contact when he threw the sign. Assault: The claim fails because the complaint does not show Mr. Hall’s intent and, as a matter of law, written threats and insults sent via mail or email cannot create the imminent apprehension of harm required for an assault claim. False Light: This claim is barred by the one-year statute of limitations, as Mayor Hall’s alleged statements were made in “early July 2022” and the lawsuit was not filed until July 26, 2023. IIED: The alleged conduct (e.g., the Old West Days incident, name-calling) is not “outrageous and intolerable” as a matter of law. They cite case law where even profane outbursts and threats in heated situations were found insufficient for an IIED claim. Civil Conspiracy: Because the underlying tort claims (assault, IIED) fail, the conspiracy claim must also fail. They also argue the claim is barred by the intra-corporate conspiracy doctrine (an entity like Woodcraft cannot conspire with its own employees like Schliesser). Vicarious Liability for Woodcraft: Woodcraft argues it cannot be held liable for Schliesser’s alleged actions because delivering threatening packages was not within the scope of his employment and did not serve the company’s business interests.
059	The Hall Parties’ Special Motion for Expedited Relief	September 5, 2024	The Halls argue Gaston’s lawsuit is an attack on free speech. The Hall parties filed an “anti-SLAPP” motion, arguing Gaston’s lawsuit was a Strategic Lawsuit Against Public Participation (SLAPP) intended to silence their political speech about his fitness for office, which is a matter of public concern. This motion was filed under Utah’s Anti-SLAPP statute, which pauses the lawsuit until (1) the defendants show that the lawsuit is based on their exercise of free speech, and (2) the plaintiff proves he has a legitimate case by establishing that sufficient evidence exists to support each essential element of each cause of action. If the defendants meet their burden, but the plaintiff doesn’t, the case must be dismissed with prejudice.	This special motion put the case on hold until the court could make a decision on it. It had the potential of disposing of Gaston’s suit; however, it was denied by the court on May 23, 2025 (Document 079).
061	Order on Motion to Extend Stay	October 3, 2024	This order granted the Hall defendants’ motion for a second pause in the lawsuit. The court extended the stay “until after the criminal trial has taken place, but no later than December 31, 2024”. The judge’s sole stated reason for granting the extension was that the criminal trial had been continued “for reasons outside the control on any party, given that the assigned prosecutor passed away”.
065	Plaintiff’s Memorandum in Opposition to the Hall Parties’ Special Motion for Expedited Relief	January 13, 2025	This is Gaston’s opposition memo to the Hall parties’ anti-SLAPP motion (Document 059). Gaston argued that the anti-SLAPP motion was filed too late. More importantly, he argued that the defendants’ communications, which were alleged to include death threats, were not protected political speech but were “true threats” of violence that are not protected by the First Amendment.
067	Reply Memorandum in Support of Defendants’ Anti-SLAPP Motion	January 27, 2025	This is the Halls’ reply to Gaston’s opposition. They argued their motion was timely because of the court-ordered stays. They contended that Gaston failed to properly address the merits and that most of their communications were protected political opinion, not “true threats”.
077	Hall Defendants’ Counterclaim and Third-Party Complaint	May 20, 2025	Jason and Natalie Hall filed a counterclaim against Gaston and a third-party complaint against Connie Pavlakis and Connie Robbins. In it, the Halls tell a story that portrays Gaston as the antagonist, alleging that he, Pavlakis, and Robbins conspired to fabricate evidence and falsely report crimes to damage the Halls’ reputation and political standing. Core Allegations of the Counterclaim: Gaston, Pavlakis, and Robbins conspired to prevent Natalie Hall’s mayoral election through a smear campaign, including authoring anonymous letters accusing her of favoritism and having an inappropriate relationship. After Jason Hall sent anonymous emails and gag gifts (like a children’s anger management workbook and a jester’s hat) criticizing Gaston’s political conduct, Gaston retaliated. Gaston fabricated a story that he received death threats from Mr. Hall, created falsified physical evidence (the threat letters), and provided it to police to frame Mr. Hall for crimes he did not commit. Gaston’s claim of being physically assaulted by Mr. Hall at the Old West Days event is false and contradicted by eyewitnesses and video evidence. Pavlakis and Robbins supported Gaston’s false narrative by giving false statements to investigators and organizing protests calling for Mayor Hall’s resignation. Causes of Action in the Counterclaim: Intentional Infliction of Emotional Distress (IIED): Against Gaston, Pavlakis, and Robbins for their alleged scheme of fabricating evidence and making false reports to police and the public. Negligent Infliction of Emotional Distress: Against Gaston, Pavlakis, and Robbins. Defamation: Against Gaston, Pavlakis, and Robbins for publishing false statements, including the alleged threats, assault, and smear letters. Abuse of Process: Against Gaston for causing criminal charges to be pursued and filing the civil action with the ulterior purpose of harassing and defaming the Halls. Civil Conspiracy: Against Gaston, Pavlakis, and Robbins for conspiring to fabricate damaging falsities to harm the Halls’ reputation and subject Mr. Hall to criminal prosecution.	This filing marked a major escalation of the feud, with the Halls suing Gaston (Counterclaim), along with his perceived Bluffdale political allies, Connie Pavlakis and Connie Robbins (Third-Party Complaint). It was filed in the midst of local political developments, 1-1/2 weeks before the beginning of the five-day window to file a Declaration of Candidacy to become a 2025 candidate for Bluffdale City municipal office. Both Natalie Hall and Connie Pavlakis filed Declarations of Candidacy for mayor.
079	Ruling and Order Denying the Hall Parties’ Special Motion for Expedited Relief	May 23, 2025	In this order, the judge denied the Halls’ anti-SLAPP motion. The court ruled that seven specific statements in the alleged communications (e.g., “If you don’t you will end up dead”) could be considered “true threats” by a jury and are therefore not the type of protected speech the anti-SLAPP law was designed to shield. The order also officially clarified that Gaston’s False Light claim was dismissed against Natalie Hall in both her personal and official capacities.	This was a significant victory for Gaston, removing the barrier imposed by the Halls’ anti-SLAPP motion and allowing the suit to proceed.
081	Plaintiff’s Memorandum in Opposition to Defendants’ Joint Motion to Dismiss	July 21, 2025	This is Gaston’s response to the defendants’ motion to dismiss his entire case (Document 058). Gaston argued that his allegations are sufficient under Utah’s pleading rules and that the defendants are improperly asking the judge to decide factual questions (like intent) that should be left for a jury.
085	Plaintiff’s Reply and Answer to Counterclaim and Third-Party Complaints	August 16, 2025	Gaston, Pavlakis, and Robbins answer to the counterclaim. Gaston, Pavlakis, and Robbins denied the Halls’ allegations, asserting that the counterclaim is a politically motivated abuse of the legal system designed to intimidate Mayor Hall’s political opponents. They raised twenty affirmative defenses.
089	Defendants’ Reply in Support of Joint Motion to Dismiss	August 22, 2025	This is the Halls’ final argument for dismissing Gaston’s case. Replying to Gaston’s opposition, the defendants argued that his complaint is legally deficient because it relies on vague, conclusory allegations and improperly groups all defendants together without specifying who allegedly did what for each claim. As of 10/6/2025, this motion is still pending before the court.
093	Third-Party Defendant’s Special Motion for Expedited Relief	September 22, 2025	Pavlakis and Robbins filed their own anti-SLAPP motion. They are asking the judge to dismiss the claims against them under Utah’s anti-SLAPP statute (UPEPA), which is designed to quickly end lawsuits that target protected free speech. Pavlakis and Robbins argued that the Halls’ claims against them are a SLAPP suit designed to silence their political speech. They claim their actions (writing letters to the city council about a public official’s conduct, protesting, and speaking to police) are protected activities concerning a matter of public concern.	Similar to the Hall’s anti-SLAPP motion, this motion puts a hold on the case that the Halls filed on May 20 against Pavlakis and Robbins (Third-Party Complaint) while the court determines whether sufficient evidence exists to support each essential element of each cause of action.
095	Hall Defendants’ Rule 26(a) Initial Disclosures	September 29, 2025	With this document, the Halls reveal their potential witnesses and evidence. In a mandatory filing, the Halls listed people they may call to testify in support of their counterclaim and to defend against Gaston’s suit. The list includes former city officials and witnesses to the Old West Days incident. They also outlined their claim for over $300,000 in damages.
098	Memorandum in Opposition to Third-Party Defendants’ Motion for Expedited Relief	October 6, 2025	The Halls argue against dismissing their case against Pavlakis and Robbins. The Halls contended that the anti-SLAPP motion of Pavlakis and Robbins was filed too late. More importantly, they argued the conduct they are suing over—defamation, fabricating evidence, and knowingly lying to police—is not protected free speech, so the anti-SLAPP statute does not apply.
100	Third-Party Defendants’ Reply Memorandum in Support of Their Special Motion for Expedited Relief	October 17, 2025	This document is likely the final written argument on the anti-SLAPP motion filed by Connie Pavlakis and Connie Robbins (Document 093). In this filing, Pavlakis and Robbins respond directly to the Halls’ opposition memo (Document 098). They argue their motion was filed on time and that the Halls’ claims should be thrown out under UPEPA because their actions—such as writing letters about a public employee, organizing protests, and speaking to investigators—are constitutionally-protected activities on matters of public concern. They also assert that the Halls’ claims are legally flawed, arguing, among other things, that their conduct does not meet the high legal standard for “outrageous” behavior for infliction of emotional distress claims and that their statements to police were accurate and about Gaston, not the Halls.