Free Proposed Pretrial Order - District Court of Colorado - Colorado

Case 1:04-cv-01122-LTB-MJW

Document 30-5

Filed 07/06/2005

Page 1 of 2

EXHIBIT 2 Defendants' Witness List (1) Nonexpert witnesses Defendants will call are as follows: a. Michael Neuman, c/o 7325 West 88th Avenue, Westminster, Colorado 80021, Tel: 303-367-0111, will testify in person as to all issues and defenses as to Plaintiff's allegations, corporate policies, his involvement in Plaintiff's termination, and the investigation of her daughter's claims. b. Colleen Brady, Human Resources Department, 1830 Route 130, Burlington, New Jersey 08016, Tel: 609-387-7800, who will appear in person as to all aspects of personnel and employment issues, including investigations, company policy, and related matters commonly performed by Human Resources personnel. c. Candie Ochoa, 7325 West 88th Avenue, Westminster, Colorado 80021, Tel: 303-431-9696, will testify in person in regard to her involvement, job duties, matters regarding both Plaintiff and Jesica Rudd, conversations with Plaintiff, her daughter, and other employees, and regarding discipline related to timecard fraud in her role as store manager. d. Raquel Romero, 3268 Depew Street, Wheat Ridge, Colorado 800212, Tel: 303-431-9696, will testify in person in regard to all matters related to Plaintiff's termination, investigations, and conversations with, or as a witness to conversations, related to this matter. (1) Witnesses Defendants may call: a. Christopher Limppo, 11102 Carlile Street, Northglenn, Colorado 80233, Tel: 303-452-8051, may testify in person as to his role as Loss Prevention Officer

Case 1:04-cv-01122-LTB-MJW

Document 30-5

Filed 07/06/2005

Page 2 of 2

related to Plaintiff's termination and other matters. b. Tammy Skurnick, 4200 Eutaw Drive, Boulder, Colorado 80303, Tel: unknown, may testify in person as to her information regarding Plaintiff and her daughter in her position as former store manager, her duties, and information related to this matter. c. Angela Bochy, address presently unknown, may testify as an assistant manager who participated in conversations and investigation of Plaintiff's conduct and acts that led to her termination and to store regarding timecard fraud. d. Chris Moore, address unknown, Tel: 303-255-2537, may testify as to his involvement in allegations made by Plaintiff and her daughter, his duties as receiving manager and related matters. e. Any witness identified by Plaintiff.