Free Proposed Pretrial Order - District Court of Delaware - Delaware

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Case 1 :04—cv—00593-GI\/IS Document 53-6 Filed 08/15/2005 Page 2 of 3 .
TAB 5
DEFENDANT’S LIST OF PERCIPIENT WITNESSES .
St gvcn G adscy <‘*’““’a“>
Michael Keller (May Call) Objection - the witness, a Dell employee,
lacks personal knowledge as to any fact that
is of consequence to the determination of
this actions (F.R.E. 401, 402, 602), and was _
never identified by Defendant as a potential
witness in disclosures or discovery. (Fed. R.
Civ. P. 26 & 33.) See Motion in Limine.
Major Horton (May Call) Objection — the witness, a Dell employee,
lacks personal knowledge as to any fact that A
is of consequence to the determination of
this actions (F.R.E. 401, 402, 602), and was
never identified by Defendant as a potential 3
witness in disclosures or discovery. (Fed. R.
Civ. P. 26 & 33.) See Motion in Limine.
Steve Thomas (May Call) Objection - the witness, an expert witness
disclosed in the Dell action, lacks personal
knowledge as to any fact that is of
consequence to the determination of this
actions (F.R.E. 401, 402, 602), is not j
qualified to provide expert testimony on any
issue of consequence to the determination of i
this action (F.R.E. 702), and was never
identified by Defendant as a potential »
witness in disclosures or discovery or Yi
designated by Defendant as an expert l
witness. (Fed. R. Civ. P. 26 & 33.) See ‘
Motion in Limine.
John LaRocca (May Call) Objection — the witness, an expert witness
disclosed in the Dell action, lacks personal
knowledge as to any fact that is of N
consequence to the determination of this Q
actions (F.R.E. 401, 402, 602), is not
qualified to provide expert testimony on (
any issue of consequence to the
determination of this action (F .R.E. 702),
and was never identified by Defendant as a
potential witness in disclosures or discovery _
or designated by Defendant as an expert
witness. (Fed. R. Civ. P. 26 & 33.) See 3
42125-003\DOCS_LA:l42335.9

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Kevin Sarkesian (May Call) Objection — the witness, a Lexmark
employee, lacks personal knowledge as to
any fact that is of consequence to the
determination of this actions (F.R.E. 401,
402, 602), and was never identified by
Defendant as a potential witness in
disclosures or discovery. (Fed. R. Civ. P. 26
& 33.) See Motion in Limine.
Any percipient witness who appears at trial on p
Plaintiffs behalf (May Call)

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