Free Proposed Pretrial Order - District Court of Colorado - Colorado

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

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EXHIBIT 1

PLAINTIFF'S WITNESS LIST

Witnesses Plaintiff will call: 1. Deborah K. Rudd, 814 West Clark Street, Livingston, Montana, 59047, (406) 222-2384. Plaintiff Rudd will be called to testify regarding most of the issues which comprise the subject matter of this lawsuit, and in particular, regarding liability and damages, Ms. Rudd will testify in person. Daniel Rudd, 814 West Clark Street, Livingston, Montana, 59047, (406) 222-2384. Mr. Rudd is Plaintiff Rudd's husband. Mr. Rudd will be called to testify regarding, without limitation, Plaintiff's employment at Burlington Coat Factory Warehouse, Plaintiff's damages, and the allegations made in Plaintiff's complaint. Mr. Rudd will testify in person. Jesica Rudd, 11550 River Run Circle, Henderson, Colorado 80640. Ms. Rudd is Plaintiff Rudd's daughter. Ms. Rudd will be called to testify regarding, without limitation, Plaintiff's employment at Burlington Coat Factory Warehouse, her own employment at Burlington Coat Factory Warehouse, the circumstances surrounding the allegations of sexual harassment made by her and the plaintiff, the circumstances surrounding Plaintiff's termination, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observation of the Plaintiff and other employees of Burlington Coat Factory Warehouse, Plaintiff's damages, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in her affidavit. Ms. Rudd will testify in person. Michael Neuman, 4603 Wildflowers Way, Castle Rock, Colorado. Mr. Neuman will be called to testify as an adverse witness regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, his involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, his own actions in this matter and in related matters, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in his deposition. Mr. Neuman is expected to testify in person. Chris Limppo, 11102 Carlile St., Northeglenn, Colorado 80233, (303) 452-8051. Mr. Limppo will be called to testify as an adverse witness regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, his involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, his own actions in this matter and in related matters, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the allegations made in Plaintiff's complaint, and regarding any other matters

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addressed in his deposition. Mr. Limppo is expected to testify in person. 6. Raquel Romero, 3268 Depew Street, Wheat Ridge, Colorado 80212. Ms. Romero will be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her own actions in this matter and in related matters, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in her deposition. Ms. Romero is expected to testify in person. Tammy Skurnik, 4200 Eutaw Drive, Boulder, Colorado 80303. Ms. Skurnik will be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in her deposition. Ms. Skurnik is expected to testify in person. Angel Garcia, 2660 West 40th Avenue, Apt. B., Denver, Colorado 80211. Ms. Garcia will be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in her affidavit. Ms. Garcia is expected to testify in person. June Dominguez, 4875 South Balsam Way, Unit 15-203, Littleton, Colorado. Ms. Dominguez will be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, the allegations made in Plaintiff's complaint, and regarding any other matters addressed in her affidavit. Ms. Dominguez is expected to testify in person.

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Witnesses Plaintiff may call: 10. Kim Listener, c/o Burlington Coat Factory Warehouse. Ms. Listener may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Listener is expected to testify in person. Carol Rediess, c/o Burlington Coat Factory Warehouse. Ms. Rediess may be called to

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testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Rediess is expected to testify in person. 12. Chris Moore. Mr. Moore may be called to testify as an adverse witness regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, his involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, his own actions in this matter and in related matters, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, and the allegations made in Plaintiff's complaint. Mr. Moore is expected to testify in person. Lovell Gerdin, c/o Burlington Coat Factory Warehouse, Mr. Gerdine may be called to testify regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Mr. Gerdine is expected to testify in person. Candie Ochoa, c/o Burlington Coat Factory Warehouse. Ms. Ochoa may be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her own actions in this matter and in related matters, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, and the allegations made in Plaintiff's complaint. Ms. Ochoa is expected to testify in person. Amanda Kilgore. Ms. Kilgore may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Kilgore is expected to testify in person. Angela (Angie) Bochy. Ms. Bochy may be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her own actions in this matter and in related matters, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, and the allegations made in Plaintiff's complaint. Ms. Bochy is expected to testify in person. Donna Donahoo. Ms. Donahoo may be called to testify regarding, without limitation, her

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employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Donahoo is expected to testify in person. 18. Teresa Young. Ms. Young may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Young is expected to testify in person. Margaret Solek, c/o Burlington Coat Factory Warehouse. Ms. Solek may be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her own actions in this matter and in related matters, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, and the allegations made in Plaintiff's complaint. Ms. Solek is expected to testify in person. Leslie Coulson, c/o Burlington Coat Factory Warehouse. Ms. Coulson may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Coulson is expected to testify in person. Colleen Brady c/o Burlington Coat Factory Warehouse. Ms. Brady may be called to testify as an adverse witness regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, her involvement with the discipline of Plaintiff and other employees, the policies and practices of Burlington Coat Factory Warehouse, her own actions in this matter and in related matters, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, and the allegations made in Plaintiff's complaint. Ms. Brady is expected to testify in person. Nate Coulson. Mr. Coulson may be called to testify regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Mr. Coulson is expected to testify in person. Erik Bohl. Mr. Bohl may be called to testify regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, the policies and

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practices of Burlington Coat Factory Warehouse, his knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Mr. Bohl is expected to testify in person.

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Alda Martinez, c/o Burlington Coat Factory Warehouse. Ms. Martinez may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Martinez is expected to testify in person. Ranee Grayson, c/o Burlington Coat Factory Warehouse. Ms. Grayson may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, the circumstances surrounding Plaintiff's termination, and the allegations made in Plaintiff's complaint. Ms. Grayson is expected to testify in person. Chris Martin. Ms. Martin may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Martin is expected to testify in person. Patricia Gurak. Ms. Gurak may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Gurak is expected to testify in person. Jessica Garner. Ms. Garner may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Garner is expected to testify in person. Ashley Turpin. Ms. Turpin may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations

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of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Turpin is expected to testify in person. 30. Kim Lujan. Ms. Lujan may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Lujan is expected to testify in person. Cristal Jimenez Ham. Ms. Ham may be called to testify regarding, without limitation, her employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, her knowledge and observations of the Plaintiff and other employees of Burlington Coat Factory Warehouse, her own allegations of sexual harassment, and the allegations made in Plaintiff's complaint. Ms. Ham is expected to testify in person. Chris Jackson. Mr. Jackson may be called to testify regarding, without limitation, his employment and conduct at Burlington Coat Factory Warehouse, the policies and practices of Burlington Coat Factory Warehouse, and his knowledge and observations of the employees of Burlington Coat Factory Warehouse. Mr. Jackson is expected to testify in person.

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