`Case 1:20-cv-00393-LO-TCB Document 654-1 Filed 05/21/21 Page 1 of 4 Page|D# 14813
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`EXHIBIT A
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`EXHIBIT A
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`Case 1:20-cv-00393-LO-TCB Document 654-1 Filed 05/21/21 Page 2 of 4 PageID# 14814
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`EXHIBIT A
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`Counterclaim Plaintiffs’ Trial Witness List
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`Counterclaim Plaintiffs provide the following witness list identifying those witnesses they
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`expect they will call, or may call, at trial, other than witnesses for rebuttal or impeachment
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`purposes, as of May 21, 2021.
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`Below, Counterclaim Plaintiffs have listed in good faith the witnesses that they expect to
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`call or may call to testify live or by prior testimony (including possibly by video) at the trial in this
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`action. For prior deposition testimony that is expect to be, or may be, read or played into evidence,
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`Counterclaim Plaintiffs have set forth separately those portions of designated testimony. (See
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`Exhibit B).
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`Counterclaim Plaintiffs reserve the right to amend and update this list, to submit as
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`appropriate, additions and/or deletions or revisions to this list as the pretrial and trial process
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`evolves, including meeting and conferring with Counterclaim Defendants on outstanding trial
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`management issues, receiving the Court’s rulings on matters such as the parties’ respective
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`evidentiary issues, to remove witnesses that prove unnecessary, and to rebut unanticipated
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`evidence presented at trial by Counterclaim Defendants. Counterclaim Plaintiffs reserve the right
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`to call any witness on Counterclaim Defendants’ witness list and any witness called by
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`Counterclaim Defendants. Counterclaim Plaintiffs reserve the right to designate and present the
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`prior deposition testimony of any witness that Counterclaim Defendants have indicated they expect
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`to testify live at trial should such witnesses not come to trial, and furthermore Counterclaim
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`Plaintiffs expressly reserve their right to introduce deposition testimony in accordance with Fed.
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`R. Civ. P. 32(a)(3).
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`Counterclaim Plaintiffs also reserve the right to call any witness not listed here as may be
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`necessary to authenticate a document to which an objection is made. Counterclaim Plaintiffs
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`Case 1:20-cv-00393-LO-TCB Document 654-1 Filed 05/21/21 Page 3 of 4 PageID# 14815
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`further reserve the right to call any person not listed here to counter surprise by any other party.
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`In addition, Counterclaim Plaintiffs reserve the right to call any person not listed here as may be
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`necessary to cure any objection to any exhibit.
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`I.
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`WITNESSES COUNTERCLAIM PLAINTIFFS WILL CALL
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`John Abraham
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`Noori Brifcani
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`Stacy Ehrlich
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`Moira Gilchrist
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`Eric Hawes
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`Kenneth Jansen
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`Michael Manson
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`Joseph McAlexander III
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`Paul Meyer
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`Robert Ripley
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`Harold Walbrink
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`II. WITNESSES COUNTERCLAIM PLAINTIFFS MAY CALL IN PERSON OR BY
`DEPOSITION
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Kara Calderon
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`Sean Daugherty
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`James Figlar
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`Grier Fleischhauer
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`Nicholas Gilley
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`Stephanie Harper
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`Eric Hunt
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`Martin King
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`2
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`Case 1:20-cv-00393-LO-TCB Document 654-1 Filed 05/21/21 Page 4 of 4 PageID# 14816
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`9.
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`10.
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`11.
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`12.
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`13.
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`Russell Kratzer
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`Henry Lam
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`Loi Ying Liu
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`John Scott Peddycord
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`Arno Rinker
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`Counterclaim Plaintiffs also reserve the right to call any person identified in Counterclaim
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`Defendants’ Witness List, the expert reports of any of Counterclaim Plaintiffs’ or Counterclaim
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`Defendants’ experts, or any of Counterclaim Plaintiffs’ or Counterclaim Defendants’ interrogatory
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`responses.
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`3
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