Free Notice of Filing Proposed Pretrial Order - District Court of Arizona - Arizona

Exhibit D United States District Court District of Arizona Defendant's Designation of Depositions Lane Sennett v. Workhorse Custom Chassis, LLC. Lane Sennett Defendant reserves the right to use any and all portions of Plaintiff's deposition transcript for impeachment purposes. William Trimmell Defendant reserves the right to use any and all portions of Mr. Trimmell's deposition transcript for impeachment purposes. Bryan Gaughan Not all pages listed may be used, and the transcript will be used as needed for impeachment and rebuttal. 8:4 ­ 11:13 12:25 ­ 13:9 16:1 ­ 17:10 19:5 ­ 22:10 23:13 ­ 26:10 28:6 ­ 28:18 56:20 ­ 57:2 92:4 ­ 94:17 107:18 ­ 110:25 113:23 ­ 114:12 179:16 ­ 180:8 Albert Carranza Not all pages listed may be used, and the transcript will be used as needed for impeachment and rebuttal. 4:12-5:10 6:8-15 21:25-23:11
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Case 2:04-cv-00161-ROS

Document 200-5

Filed 08/25/2006

Page 1 of 2

24:22-24 Defendant also will read for the jury the affidavit provided by Mr. Carranza dated March 2, 2005. This affidavit was specifically requested by Plaintiff and ordered to be provided by the Court. Plaintiff subsequently deposed Mr. Carranza and cross-examined him on the contents of the affidavit. Mr. Carranza authenticated the testimony set forth in his affidavit and has set forth his affirmation to swear to the contents of said affidavit. Robert Zulian Defendant will call Mr. Zulian live as a witness at trial, but reserves the right to use all or part of his deposition transcript if in the unforeseeable event he is unavailable to testify at trial.

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Case 2:04-cv-00161-ROS

Document 200-5

Filed 08/25/2006

Page 2 of 2