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Envelope-to: [email protected] X-Spam-Checker-Version: SpamAssassin 3.1.0 (2005-09-13) on grafias.lunarpages.com X-Spam-Level: * X-Spam-Status: No, score=1.5 required=5.0 tests=AWL,INVALID_MSGID autolearn=no version=3.1.0 Alternate-recipient: Prohibited Disclose-recipients: Prohibited Date: Thu, 02 Mar 2006 11:45:45 -0500 (EST) From: "[email protected]"
Steve Are you going to submit any evidence or affidavits in support of Defendant's dispositive motion from any of the undeposed witnesses listed below? Kieron
Printed for Kieron Quinn
3/2/2006
[email protected], 11:45 AM 3/2/2006, RE: Final Witness Lists Case 1:01-cv-00201-VJW Document 151-3 Filed 03/03/2006
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======================================================================== At 05:03 PM 3/1/2006, you wrote: >Kieron, > >To confirm our conversation regarding final witness lists, we agreed >to postpone exchanging final witness lists pending the court's >ruling on our motion to extend. > >You indicated that plaintiffs did not intend to add any witnesses to >your list and you asked me to provide the names of those witnesses >we expect to add, which include: > >New witnesses: > >CDR Richard Erie - replaces CDR David Desimone (No. 2) on >list. Topics of expected testimony remain the same. For >clarification, CDR Erie recently replaced CDR Desimone as the NASO >Air Ops officer. > >CDR (ret.) Frank Kraemer, former NAS Oceana Air Operations Officer >relevant period early 1990's - same topics as Wulf and Jenkins > >CDR (ret) Lawrence Hurley, former NAS Oceana Air Traffic Control >Facility Officer - relevant period late 1980's - same topics as Wulf >and Jenkins > >CDR Robert F. Collins, former NAS Oceana Air operations Officer >relevant period late 1980's - same topics as Wulf and Jenkins > >Lloyd Wilkinson - may testify about management of data used by Hank >Wise, if necessary. > >Custodian of Records for REIN database - reserve the right to call >this person, if necessary. > >Joe Czech - may testify regarding noise analyses at NAS Oceana by >Wyle Laboratories > >Modifications to topics of expected testimony of current witnesses: > >LCDR Wulf (No. 3) and CWO Jenkins (No. 6) - may also testify >regarding the reporting and recording of aircraft operations numbers. > >Nick Miller (No. 25) - potential witness on merits rather than >rebuttal exclusively. May testify about 1978 AESO report as well as >HMMH studies already mentioned in current list. > >Capt Keeley (No. 30) - may also testify regarding the other topics >in CDR Erie's and Hebert's descriptions. >
Printed for Kieron Quinn
3/2/2006
[email protected], 11:45 AM 3/2/2006, RE: Final Witness Lists Case 1:01-cv-00201-VJW Document 151-3 Filed 03/03/2006 >When we do finalize the witness list there may be some modifications >to the topics of the testimony, or potentially additional witnesses >added or deleted, but as I mentioned these are the expected changes >right now. We will also amend the list to reserve the right to call >any plaintiff, not just test plaintiffs. > >Regards, > >Steve
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Printed for Kieron Quinn
3/2/2006
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