Free Witness List - District Court of Connecticut - Connecticut

Case 3:01-cv-02403-AHN

Document 8

Filed 03/24/2004

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SEACO INSURANCE COMPANY a/s/o CORNER HOUSE ASSOCIATES, LLP Plaintiff v. LIGHTOLIER, a division of GENLYTE THOMAS GROUP, LLC Defendant : : : : : : : : : : :

CASE NO. 3:01 CV 197 (AHN)

MARCH 24, 2004

DESIGNATIONS OF PORTIONS OF DEPOSITIONS TO BE READ AT TRIAL

Pursuant to the Court's Pretrial Order, the defendant, Lightolier, hereby files its designation of deposition transcript testimony which it may offer, if necessary, during the trial in the above-referenced matter: 1. Portions of the deposition testimony of Dan Slowick:

The defendant intends to designate portions of the deposition transcript of Dan Slowick in the event that plaintiff does not stipulate as to the location where Mr. Slowick's exemplar light fixture was located at the fire scene at the time of the fire. Similarly, the relevant portions of the Slowick deposition testimony will be designated in the event that the parties do not stipulate with respect to the position of the "end cap" of the Slowick exemplar at the time that the exemplar came into the possession of Mr. Slowick. To the extent that the parties cannot stipulate with respect to the authenticity of the photographs taken by Dan Slowick, then portions of his deposition testimony will be designated to authenticate and, perhaps, position the Slowick photographs at the fire scene. It is anticipated that the parties will be able to stipulate to the above, however.

Case 3:01-cv-02403-AHN

Document 8

Filed 03/24/2004

Page 2 of 3

2.

Portions of the deposition testimony of Ronald Mullen:

The defendant intends to designate portions of the deposition transcript of Ronald Mullen in the event that plaintiff does not stipulate as to the location where the exemplar light fixture was located at the fire scene at the time of the fire. To the extent that the parties cannot stipulate with respect to the authenticity of the photographs taken by Ron Mullen at the fire scene, then portions of his deposition testimony will be designated to authenticate and, perhaps, position the Mullen photographs at the fire scene. It is anticipated that the parties will be able to stipulate to the above, however. 3. Portions of the deposition testimony of Joseph Cristino:

The portions of the deposition testimony of Joseph Cristino which were reviewed by Fire Marshal Vincent DiPietro and referenced in his Affidavit dated February 17, 2004. 4. Portions of the deposition testimony of Thomas Haynes:

The portions of the deposition testimony of Thomas Haynes which were reviewed by Fire Marshal Vincent DiPietro and referenced in his Affidavit dated February 17, 2004.

Dated: March 24, 2004

RESPECTFULLY SUBMITTED, LIGHTOLIER, a division of GENLYTE THOMAS GROUP, L.L.C.,

By:

____________________________________ Frederick B. Tedford (ct05335) TEDFORD & HENRY, LLP 750 Main Street Hartford, CT 06103 Phone (860) 293-1200 Fax (860) 293-0685 Attorneys for the Defendant [email protected]

Case 3:01-cv-02403-AHN

Document 8

Filed 03/24/2004

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CERTIFICATION I hereby certify that a copy of the foregoing was served, via U.S. Mails, proper postage affixed, on this 24th day of March, 2004, to all counsel and pro se parties of record addressed to the following: Justin J. Donnelly, Esq. Law Offices of Stuart G. Blackburn Two Concorde Way P.O. Box 3216 Windsor Locks, CT 06096 Robert W. Cassot, Esq. Morrison, Mahoney & Miller, LLP One Constitution Plaza, 10th Floor Hartford, CT 06103 ____________________________________ Frederick B. Tedford