`Case 1:20-cv-00393-LO-TCB Document 1328-2 Filed 06/11/22 Page 1 of 3 PagelD# 33590
`
`EXHIBIT 8
`EXHIBIT 8
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 1328-2 Filed 06/11/22 Page 2 of 3 PageID# 33591
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Confirmed.
`
`Maiorana, David M. <dmaiorana@JonesDay.com>
`Thursday, June 9, 2022 7:25 PM
`Sandford, Brett (Bay Area); Michalik, John M.; #C-M PMIEDVA - LW TEAM
`RJREDVA; cmolster@molsterlaw.com
`RE: Case No. 1:20-cv-00393-LO-TCB (Reynolds's June 9 trial disclosure)
`
`David M. Maiorana (bio)
`Partner
`JONES DAY® - One Firm Worldwide℠
`901 Lakeside Ave.
`Cleveland, OH 44114
`Office: 1.216.586.7499
`Email: dmaiorana@jonesday.com
`
`From: Brett.Sandford@lw.com <Brett.Sandford@lw.com>
`Sent: Thursday, June 9, 2022 7:14 PM
`To: Michalik, John M. <jmichalik@JonesDay.com>; pmiedva.lwteam@lw.com
`Cc: RJREDVA <RJREDVA@jonesday.com>; cmolster@molsterlaw.com
`Subject: RE: Case No. 1:20-cv-00393-LO-TCB (Reynolds's June 9 trial disclosure)
`
`** External mail **
`
`John,
`
`We understand from Mr. Grant’s discussions with Mr. Maiorana that the omission of Dr. Sullivan from your disclosure below
`means that Reynolds will not call Dr. Sullivan at trial. Please confirm by 7:30 pm.
`
`Regards,
`
`Brett M. Sandford
`LATHAM & WATKINS LLP
`505 Montgomery Street | Suite 2000 | San Francisco, CA 94111-6538
`D: +1.415.395.8150
`
`From: Michalik, John M. <jmichalik@JonesDay.com>
`Sent: Thursday, June 9, 2022 7:01 PM
`To: #C-M PMIEDVA - LW TEAM <pmiedva.lwteam@lw.com>
`Cc: RJREDVA <RJREDVA@jonesday.com>; cmolster@molsterlaw.com
`Subject: Case No. 1:20-cv-00393-LO-TCB (Reynolds's June 9 trial disclosure)
`
`Counsel - -
`
`1
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 1328-2 Filed 06/11/22 Page 3 of 3 PageID# 33592
`
`Reynolds discloses that it intends to call the following witnesses to testify in its case-in-chief and rebuttal case, in the following
`order (to be called on specific days as time permits).
`
`
`• Kelly Kodama
`• Edward Kiernan (by deposition)
`• Eric Hunt
`•
`Jeffrey Suhling (on Monday as stated in Court today)
`
`
`In addition, Reynolds discloses the attached demonstratives that may be used with Mr. Hunt. Reynolds also identifies the
`following exhibits that may be offered into evidence or used during the testimony of Mr. Hunt.
`
`Hunt
`
`PPX-003
`PPX-004
`PPX-008
`PPX-009
`
`
`John M. Michalik
`Partner
`JONES DAY® - One Firm Worldwide℠
`110 North Wacker Drive
`Suite 4800
`Chicago, Illinois 60606
`Office +1.312.269.4215
`Mobile +1.312.315.5926
`jmichalik@jonesday.com
`
`***This e-mail (including any attachments) may contain information that is private, confidential, or protected by
`attorney-client or other privilege. If you received this e-mail in error, please delete it from your system without copying
`it and notify sender by reply e-mail, so that our records can be corrected.***
`_________________________________
`
`This email may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended
`recipient. Any review, disclosure, reliance or distribution by others or forwarding without express permission is strictly
`prohibited. If you are not the intended recipient, please contact the sender and delete all copies including any attachments.
`
`Latham & Watkins LLP or any of its affiliates may monitor electronic communications sent or received by our networks in order
`to protect our business and verify compliance with our policies and relevant legal requirements. Any personal information
`contained or referred to within this electronic communication will be processed in accordance with the firm's privacy notices
`and Global Privacy Standards available at www.lw.com.
`***This e-mail (including any attachments) may contain information that is private, confidential, or protected by
`attorney-client or other privilege. If you received this e-mail in error, please delete it from your system without copying
`it and notify sender by reply e-mail, so that our records can be corrected.***
`
`2
`
`
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