`Case 2:21-cv-00040-JRG Document 211-5 Filed 01/25/22 Page 1 of 3 PagelD #: 9745
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`EXHIBIT E
`EXHIBIT E
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`Case 2:21-cv-00040-JRG Document 211-5 Filed 01/25/22 Page 2 of 3 PageID #: 9746
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`Exhibit C: GTP’s Objections to Defendants’ Trial Witness List
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`Pursuant to Federal Rule of Civil Procedure 26(a)(3)(A) and the Sixth Amended Docket
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`Control Order (Dkt. No. 155), Gesture Technology Partners, LLC (“GTP”) hereby submits the
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`following objections to Defendants’ trial witness list.
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`GTP objects to Defendants’ Trial Witness List because it fails to comply with the Sixth
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`Amended Docket Control Order (Dkt. No. 155) by identifying witnesses that are not relevant to the
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`issues on which Defendant holds the burden of proof. GTP reserves the right to modify, amend, or
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`supplement these objections throughout the balance of this case. GTP also reserves the right to
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`supplement these objections in response to rulings by the Court (including on any motions).
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`GTP objects to Defendants’ identification of “will call” witnesses that are not relevant to the
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`issues on which Defendant holds the burden of proof as failing to give GTP fair notice of the witnesses
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`that Defendant expects to present at trial and prejudicing GTP’s ability to prepare for trial. GTP
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`objects to Defendants’ identification of witnesses that were not timely disclosed to GTP. GTP
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`specifically objects to the following witnesses:
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`1.
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`Joengho Cho: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`2.
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`Sean Diaz: GTP objects to this witness as having no relevant testimony for the issues
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`on which Defendant holds the burden of proof.
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`3.
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`Bong-June Kang: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`4.
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`Yonggyoo Kim: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`-1-
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`Case 2:21-cv-00040-JRG Document 211-5 Filed 01/25/22 Page 3 of 3 PageID #: 9747
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`5.
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`Ryanggeun Oh: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`6.
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`Timothy Pryor: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`7.
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`Joseph Repice: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`8.
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`Byungyun Son: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`9.
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`Juwoan Yoo: GTP objects to this witness as having no relevant testimony for the
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`issues on which Defendant holds the burden of proof.
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`10.
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`Keith Ugone: GTP objects to this witness GTP objects to this witness as having no
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`relevant testimony for the issues on which Defendant holds the burden of proof.
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`-2-
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