Free Proposed Pretrial Order - District Court of Delaware - Delaware

Case 1:06-cv—OOO55-G|\/IS Document 176-11 Filed 05/O2/2007 Page 1 014
SCHEDULE D—3
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Case 1 :06-cv—OOO55-GIVIS Document 176-11 Filed 05/O2/2007 Page 2 of 4
SCHEDULE D—3
DEFENDAN T WALDMANN’S WITNESS LIST
AND PLAINTIFF’S OBJECTIONS THERETO .
I. Witnesses Defendant Waldmann lntends to Call at Trial
Name and Address Objections (if any)
David Masilotti (as on cross)
Tesla Industries, Inc.
109 Centerpoint Boulevard
New Castle, DE
Truee Dorsey (as on cross)
Tesla Industries, Inc.
109 Centerpoint Boulevard
New Castle, DE
Frank Mooney (as on cross)
Tesla Industries, Inc.
109 Centerpoint Boulevard
New Castle, DE
Malvern, PA .
Davidwtmm _
Austin, TX "
Portland, OR
Mrs. David C. Waldmann
6 Robin Road
Malvern, PA 19355 ?
Bob Frankenheimer Tesla objects to the testimony of this person _ Q
Employee of Frankenheimer Landscaping who is a landscaper by profession. His .
Address Unknown knowledge and experience is unrelated to the
issues in this case and therefore his testimony
would be irrelevant and a waste ofthe court’s
time
David Cassity Tesla objects to Mr. Cassity’s testimony for the
101st Airborne Division reasons stated in a recent communication from
United States Army U.S. Army JAG which notes restrictons on the
testimony of active duty personnel absent a
waiver from the Army. Since no waiver has
been proffered Mr Cassity is disqualified
from providing testimony in this action.

Case 1 :06-cv—0OO55-GIVIS Document 176-11 Filed 05/02/2007 Page 3 of 4
Reynaldo G. Batipps
47042 Tate Road
Toturent River, MD
Joseph Talbot Tesla objects to this witness’ testimony to the
Marketing Manager extent it might involve disclosure of Tesla
Tesla Industries, Inc. confidential information to anyone other than
109 Centerpoint Boulevard Tesla and its authorized representatives during
New Castle, Delaware 19720-4180 preparation for trial, or at trial.
Tesla objects to this witness’ testimony to the
Tom Adams extent it might involve disclosure of Tesla
Fenner Tesla Employee confidential information to anyone other than .
Address Unknown Tesla and its authorized representatives during ‘
preparation for trial, or at trial. ;
Dave Holden Tesla objects to this witness’ testimony to the
Former Tesla Employee extent it might involve disclosure of Tesla
Address Unknown confidential information to anyone other than
Tesla and its authorized representatives during 5
preparation for trial, or at trial.
David Gresk Tesla objects to this witness’ testimony to the
654 Sunset Avenue extent it might involve disclosure of Tesla
Franklinville, NJ confidential information to anyone other than
Tesla and its authorized representatives during
preparation for trial, or at trial. K
Dave Brown l
United States Army Representative
Fort Knox
Dana Kelly The same objection regarding testimony of
160th Special Operations Aviation Regiment active duty Army personnel is repeated and
United States Anny lodged with respect to this witness
Waldmann hereby incorporates the witness provided by NMT and By Tesla.

Case 1 :06-cv—OOO55-GIVIS Document 176-11 Filed 05/O2/2007 Page 4 of 4
II. Witnesses Plaintiff May Call at Trial
Name and Address Objection (if any)
__
Daniel Rosciolli (as on cross)
Tesla Industries, Inc.
New Castle, DE
David Gresk Tesla objects to this witness’ testimony to the
654 Sunset Avenue extent it might involve disclosure of Tesla
Franklinville, NJ confidential information to anyone other than
Tesla and its authorized representatives during
preparation for trial, or at trial.
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