Free Proposed Pretrial Order - District Court of Delaware - Delaware

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Case 1:06-cv—OOO55-G|\/IS Document 176-10 Filed 05/O2/2007 Page 1 014
SCHEDULE 1)-2
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Case 1 :06-cv—OOO55-GIVIS Document 176-10 Filed 05/O2/2007 Page 2 of 4
UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
TESLA INDUSTRIES, INC. a Delaware
Corporation,
Plaintiff
v. C.A. No. 06~55—GMS
DAVID C. WALDMANN, LYNDOL W.
HOLLINGSWORTH, CHARLES MINNICK
a.k.a. CHUCK MINNICK, and NEW
MILLENNIUM TOOLS, INC., an Oregon
Corporation,
Defendants.
SCHEDULE D-2:
WITNESS LIST OF DEFENDANTS LYNDOL W. HOLLINGSWORTH,
CHARLES MINNICK AND NEW MILLENNIUM TOOLS, INC. AND
PLAINTIFFS’S OBJECTIONS THERETO
Defendants Lyndol W. Hollingsworth, Charles Minnick and New Millennium
Tools, Inc. (collectively, the "NMT Defendants"), hereby submit their witness list as of
May 2, 2007. The NMT Defendants reserve the right to submit, as appropriate, additions
and/or revisions to their witness list as the pretrial and trial process evolves, including
receiving the Court's rulings on matters such as the parties' respective motion in limine.
The NMT Defendants reserve the right to call any witness on Plaintiffs witness list and
any witness called by Plaintiff.
Plaintiff objects to any attempted reservation of a right to amend their trial
witness list.

Case 1 :06-cv—00055-GIVIS Document 176-10 Filed 05/02/2007 Page 3 of 4
I. WTTNESSES THE NMT DEFENDANTS INTEND T0 CALL AT TRIAL
NAME AND ADDRESS OBJECTIONS (IF ANY)
Charles Minnick
8420 SW 89th Ave.
Portland, OR 97223
1305 Crows Nest Ct. ‘
Azle, TX 76020
David C. Waldmann
6 Robin Road
Malever, Pennsylvania 19355
II. WITNESSES THE NMT DEFENDAN TS INTEND T0 CALL LIVE OR BY
DEPOSITION, PURSUANT TO FED. R. CIV. P. 32(A) AND/OR FED. R.
EVID. 801(D)(2), 807 AND 1007* ittt’ M i’‘’ it " ‘‘‘‘ti ‘"""
David J. Masilotti
CHIEF EXECUTIVE OFFICER
Tesla Industries, Inc.
Frank Mooney
GENERAL SALES MANAGER
Tesla Industries, Inc.
109 Centerpoint Blvd.
New Castle, Delaware 19720
Daniel Roscioli
NIARKETING MANAGER
Tesla Industries, Inc.
109 Centerpoint Blvd.
New Castle, Delaware 19720 ,
Joseph Talbot
MARIQETING MANAGER
Tesla Industries, Inc.
109 Centerpoint Blvd.
New Castle, Delaware 19720 i
Kent F. Huffman
PRESIDENT
DC Power Equipment, LLC
8868 Research Blvd., Suite 505
Austin, Texas 78758
* See NMT Defendants Schedule F for the deposition designations for each witness under Section II.

Case 1 :06-cv—OOO55-GIVIS Document 176-10 Filed 05/O2/2007 Page 4 of 4
HI. WITNESSES THE NMT DEFENDANTS MAY CALL AT TRIAL
NAME AND ADDRESS OBJECTIONS (IE ANY)
David Fantasia HE WAS NOT LISTED AS A POTENTIAL
Bethlehem, PA 18017 WITNESS IN INITIAL DISCLOSURES NOR IN
RESPONSE TO DISCOVERY. TESLA OBJECTS
TO USE OF THIS LATE DISCLOSED WITNESS
AT TRIAL EOR TEE SAME REASONS
ADVANCED IN DEFENDANTS° MOTION IN
L1"MINE(D..I. 133)