Free Proposed Pretrial Order - District Court of Delaware - Delaware

Case 1:06-cv—OOO55-G|\/IS Document 176-12 Filed 05/O2/2007 Page 1 013
SCHEDULE E

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SCHEDULE E
PLAINTIFF’S STATEMENT OF ITS EXPERT W'ITNESS’
QUALIFICATIONS AND NlVIT DEFENDANT’S OBJECTIONS THERETO
1. Clyde T. Carter (Plaintiff) - Mr. Carter is a mechanical engineer with over forty
years of design experience, with a specialty in new product analysis and reduction to practice.
A Mr. Carter received his Bachelor of Science in Mechanical Engineering from Fairleigh
Dickinson University and has completed graduate studies at the General Electric Company. His
career company affiliations include Bell Telephone Laboratories, General Electric Company,
i Goodyear Atomic Corporation, AMP Incorporation, Mark Products, Sealectro Corporation,
Burndy Corporation and Wells Electronics. Mr. Carter is the holder of numerous patents in the
connector and related fields, and has authored several technical papers. While at Wells
Electronics, Mr. Carter served as Director of Research & Development and General Manager of $
their Product Development Center, specializing in Burn—In connectors including Zero Insertion
Force and Pin Grid Array Applications.
2. Donald T. Stewart (Plaintiff) — Prior to retiring in 2006, Mr. Stewart had a twenty-
six-year career with the military, the past seven of which he served as Team Leader for Tool sets
and management expert for tool optimization. In this capacity, he had been actively involved in
military procurement of equipment, providing detailed analysis for the current tool sets, kits and
outfits. From 1995-2005 he served as Mobile Shop Set Team Leader and Team Leader of the
Chemical Defense Equipment division from 1989-1995, where he was director of support for the ·
Service Response Force, an ad—hoc group of experts from the government and Army trained to
respond to any accident or incident worldwide. Mr. Stewart also served in operation Desert
Shield and Desert Storm as the Anny’s chemical liaison oiticer, and was the only civilian to do
so.

Case 1 :06-cv—OOO55-GIVIS Document 176-12 Filed 05/O2/2007 Page 3 of 3
3. Robert Guillemette (Plaintiff) - Officer Guillemette has been serving in the United
States Army for the past twenty-three years. Since 2004, he has served as an Army Instructor,
Writer and Equipment Analyst. His duties include teaching logistical professional development
and technical trouble shooting, evaluating and analyzing new military equipment, consulting
with potential defense contractors to analyze technical data, and evaluating new innovations to
technology and equipment. Prior to serving in this capacity, Officer Guillemette was a
Logistician and Maintenance Manager from 1996 to 2005, and an army mechanic and non
· commissioned officer from 1984 to 1996. p
4. John P. Sullivan (Plaintiff`) — Mr. Sullivan is currently employed as Valuation
Consultant and Audit Director for Cordua & Company, P.C. a certified public accounting firm
located in Pennsauken, New Jersey. Mr. Sullivan received his Bachelor of Science degree Horn
Villanova University in 1998. Prior to joining Cordua & Company, Mr. Sullivan was a financial
auditor for the Campbell Sales Company from 2001 to 2002, and a senior auditor with Ernst &
Young, LLP from 1997-2000.
The NMT Defendants' Objections:
The NMT Defendants incorporate by reference their Dczubert Motion (DJ. 170-171) and
request that any ruling thereon apply to each expert identified in Plaintiffs Statement of its
Expert Witness’ Qualifications.
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