Free Proposed Pretrial Order - District Court of Colorado - Colorado

Case 1:04-cv-01160-LTB-CBS

Document 96-2

Filed 04/21/2006

Page 1 of 2

Attachment A to Final Pretrial Order DerKevorkian v. Lionbridge Civil Action No. 04-cv-01160-LTB-CBS Plaintiff's witnesses: (a) will be present at trial: (i) Isabelle DerKevorkian. She will testify about all matters at issue and in accordance with her deposition. In person. (b) may be present at trial: (i) Jenni Tymkovich. She will testify in accordance with her deposition. In person.

(ii) Barbara Peralta. She will testify in accordance with her deposition. In person. (iii) Yves Lang, 4584 Maple Court, Boulder, CO 80301; 303-516-9543. He may testify about how Plaintiff has been affected by the loss of her job and her move from the United States. In person. (c) by means of a deposition: (i) Sharryn Ross. She will testify in accordance with her deposition.

Defendant's witnesses: (a) will be present at trial: (i) Margaret Shukur (client representative). She may testify about Plaintiff's demands. In person. (b) may be present at trial: (i) Jenni Tymkovich. 3500 Center Green Drive, Boulder, CO 80301. She may testify regarding Plaintiff's claims. In person. (ii) Barbara Peralta. 1012 Tantra Park Circle, Boulder, CO 80301. She may testify regarding Plaintiff's claims. In person. (iii) Sharryn Ross, 59 Temple Place, Suite 605, Boston, MA 02111; She may testify about advice given regarding Plaintiff's potential green card application and her reasons therefore. In person. 1

Case 1:04-cv-01160-LTB-CBS

Document 96-2

Filed 04/21/2006

Page 2 of 2

(iv) Michele Erwin. As vice president of human resources for Defendant, Ms. Erwin may testify regarding Defendant's policies, administration of the PRP, and Plaintiff's application for a green card. (v) Impeachment witnesses and witnesses necessary to lay a foundation

(c) by means of a deposition: (i) Plaintiff. She will testify in accordance with her deposition.

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