Free Expert Witness Designation - District Court of Colorado - Colorado

Case 1:04-cv-01263-REB-KLM

Document 139

Filed 08/11/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01263-PSF-MEH ROBERT M. FRIEDLAND, Plaintiff, v. TIC ­ THE INDUSTRIAL COMPANY; GEOSYNTEC CONSULTANTS INC. f/k/a GEOSERVICES, INC. Defendants.

PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES RE: DAMAGES

Plaintiff, Robert M. Friedland, pursuant to F.R.C.P. 26(a)(2) and the Case Management Order, hereby designates the following expert witnesses in connection with the issue of damages: 1. Andy Davis, PhD Geomega, Inc. 2995 Baseline Road, Suite 202 Boulder, Colorado 80303 303-443-9117

If called, Mr. Davis will testify with regard to the matter of damages as set forth in his expert report (a copy of which is provided to Defendants this same date, and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony he may give in this case.

Case 1:04-cv-01263-REB-KLM

Document 139

Filed 08/11/2006

Page 2 of 4

2.

Kenneth L. Meyers, P.E. The MINES Group, Inc. 1325 Airmotive Way, Suite 175U Reno, Nevada 89502 775-322-7622

If called, Mr. Meyers will testify with regard to the matter of damages set forth in his expert report (a copy of which is provided to Defendants this same date, and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony he may give in this case. 3. Christopher M. Wittenbrink CR Consulting, Inc. 6222 Chimney Rock Trail Morrison, CO 80465 303-697-3398

If called, Mr. Wittenbrink will testify with regard to the matter of damages set forth in his expert report (a copy of which is provided to Defendants this same date, and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony he may give in this case. 4. Garth H. Allen, J.D., C.P.C.U. 1633 Glenmere Blvd. Greeley, CO 80631 970-351-1234

If called, Mr. Allen will testify with regard to the matter of damages set forth in his expert report (a copy of which is provided to Defendants this same date, and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony he may give in this case.

-2-

Case 1:04-cv-01263-REB-KLM

Document 139

Filed 08/11/2006

Page 3 of 4

5.

Kurt D. Fesler, CPA PricewaterhouseCoopers LLP 1670 Broadway, Suite 1000 Denver, CO 80202-4870 720-931-7291

If called, Mr. Fesler will testify with regard to the matter of damages as set forth in his expert report (a copy of which is provided to Defendants this same date, and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony he may give in this case. 6. Document and deposition discovery pertaining to the damage issues in this case is

ongoing and, therefore, Mr. Friedland reserves the right to supplement or amend this Designation of Expert Witnesses Re: Damages and the reports that have been provided to Defendants based on additional information uncovered as discovery in this case progresses. 7. Mr. Friedland further reserves the right to offer foundation testimony as well as

expert rebuttal testimony as necessary and to use at trial any testimony given by any expert witness designated by any Defendant in this lawsuit. RESPECTFULLY SUBMITTED this 11th day of August 2006.

/s/ R. Kirk Mueller John D. Fognani, Esq. R. Kirk Mueller, Esq. Perry L. Glantz, Esq. Kristina I. Mattson, Esq. FOGNANI & FAUGHT, PLLC 1700 Lincoln Street, Suite 2222 Denver, CO 80203 Attorneys for Plaintiff

-3-

Case 1:04-cv-01263-REB-KLM

Document 139

Filed 08/11/2006

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on this 11th day of August 2006, a true and correct copy of the foregoing PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES RE: DAMAGES was electronically filed via ECF with the U.S. District Court for the District of Colorado and served electronically or via U.S. Mail, postage prepaid, on the following: Terrence M. Ridley, Esq. Steven M. Kelso, Esq. Wheeler Trigg Kennedy, LLP 1801 California Street, Suite 3600 Denver, CO 80202-2617 Colin C. Deihl, Esq. Faegre & Benson, LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80202-4532 Paul J. Sanner, Esq. Hanson, Bridgett, Marcus, Vlahos & Rudy, LLP 333 Market Street, Suite 2100 San Francisco, CA 94105-2122

/s/ C.S. Vega