Free Expert Witness Designation - District Court of Colorado - Colorado

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

Document 102

Filed 04/10/2006

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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 GEOSYNTEC, INC. Defendants.

DEFENDANT TIC'S DESIGNATION OF EXPERT WITNESSES

Defendant, TIC ­ The Industrial Company ("TIC"), pursuant to F.R.C.P. 26(a)(2) and the Court's Scheduling Order, as amended, hereby designates the following expert witnesses in connection with liability: 1. Patrick J. Fox, Ph.D., Professor, Department of Civil & Environmental

Engineering & Geodetic Science, Ohio State University, 495A Hitchcock Hall, Ohio State University, Columbus, Ohio 43210, (614) 688-5695. If called, Mr. Fox will testify with regards to matters set forth in his expert report (a copy of which is provided the other parties this same date and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony given in this case. 2. Pressley L. Campbell Ph.D., PE, Conestoga-Rovers & Associates, Inc.,

4915 S. Sherwood Forest Blvd., Baton Rouge, Louisiana 70816, (225) 292-9007. If called,

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

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Mr. Campbell will testify with regards to matters set forth in his expert report (a copy of which is provided the other parties this same date and is incorporated herein by reference), including any supplementation thereof, as well as all matters covered in any deposition testimony given in this case. 3. TIC reserves the right to offer any expert rebuttal testimony necessary and to use

at trial any testimony given by any expert witness designated by any party in this lawsuit. 4. Discovery in this case is ongoing, and therefore TIC reserves the right to

supplement or amend its designation and the reports referenced herein based on additional information uncovered during discovery. 5. The Court entered an Order staying the deadline for Plaintiff to designate expert

witnesses on damage issues until after the Court decides GeoSyntec's pending Motion to Bifurcate. Therefore, TIC reserves the right to designate damages or allocation experts and/or to supplement the reports of the expert witnesses designated herein with regard to damages allocation issues after Plaintiff designates such experts.

Respectfully submitted this 10th day of April 2006.

s/ Colin C. Deihl Colin C. Deihl, Esq. Faegre & Benson, LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80202-4532 Attorneys for Defendant TIC

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Document 102

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CERTIFICATE OF SERVICE I hereby certify that on this 10th day of April 2006, a true and correct copy of the foregoing DEFENDANT TIC'S DESIGNATION OF EXPERT WITNESSES was electronically filed via ECF with the U.S. District Court for the District of Colorado and served electronically or via first-class U.S. mail on the following: John D. Fognani, Esq. R. Kirk Mueller, Esq. Lauren C. Buehler, Esq. Fognani & Faught, PLLC 1700 Lincoln Street, Suite 2222 Denver, Colorado 80203 Terrence M. Ridley, Esq. Steven M. Kelso, Esq. Wheeler Trigg Kennedy, LLP 1801 California Street, Suite 3600 Denver, CO 80202-2617 Paul J. Sanner, Esq. Hanson, Bridgett, Marcus, Vlahos & Rudy, LLP 333 Market Street, Suite 2100 San Francisco, CA 94105-2122

s/ Jan Sullivan
DNVR1:60341296.01