Mirror Worlds, LLC v. Apple, Inc.
Trial Witness List by Apple, Inc.. (Randall, Jeffrey)
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. JURY TRIAL DEMANDED Civil Action No. 6:08-cv-88 LED
DEFENDANT AND COUNTERCLAIM DEFENDANT APPLE INC.'S TRIAL WITNESS LIST
Pursuant to the Court's Docket Control Order entered in this matter, Defendant and Counterclaim Plaintiff Apple Inc. ("Apple") hereby respectfully submits its Trial Witness List. At this time, Apple identifies the following witnesses for Trial that will appear either live and/or by deposition: Witness Bud Tribble Gitta Salomon Will Call X X May Call By deposition videotape or transcript X Live (if available) X X
Witness Richard Mander Kevin Tiene John Hornkvist Dominic Giampaolo Nitin Ganatra Dave Heller Jeff Robbin Thomas Goossens Bill Bachman Greg Christie Pavel Cisler Brian Croll Greg Joswiak Steve Feiner Keith Ugone Marc Frapier Edward Belove Christopher Schmandt Mark Lansdale Peter Lucas Nancy Silver Ron Baecker, Ph.D. David Gelernter Nancy Pellegrino Chris Hatchell Nicholas Carriero Ed Stone Richard Raich Julie Teodosio Eric Freeman Christopher Jones Richard Milner Frank Weil Ivan Kavrukov Peter Sparago Randy Prager Michael Satow Lou Nemeth Corporate representative of Mirror Worlds Technologies, Inc.
May Call X
X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X
By deposition videotape or transcript X X X X X X X X X X X X X
Live (if available) X X X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X X X X X
Witness Corporate representative of Mirror Worlds LLC
May Call X
By deposition videotape or transcript X
Live (if available) X
Apple reserves the right to further supplement their identification of trial witnesses with additional fact and expert witnesses as may be disclosed in subsequent discovery. As of the date of this filing, discovery, including depositions, is still ongoing. In addition, Apple reserves the right to call any fact and/or expert witness(es) to rebut evidence offered by Plaintiff Mirror Worlds, LLC, ("Plaintiff") in its case-in-chief. Apple reserves the right to call any witness listed on Plaintiffs' Witness List. Apple reserves the right to withdraw any fact or expert witness(es) before or during trial. For Apple's "may call" witnesses, Apple does not currently have information on each of the witnesses' availability for trial or the burden that it would place on them to appear at trial. In accordance with the Court's Docket Control Order, Apple may also introduce testimony via designated portions of depositions, including portions of depositions of Plaintiff's Fed. R. Civ. P. 30(b)(6) designee(s), portions of depositions of witnesses affiliated or associated with Plaintiffs, and portions of depositions of unavailable witnesses. Apple shall provide its designations in accordance with the timing set forth in the Court's Docket Control Order.
Dated: June 16, 2010
Respectfully submitted, PAUL, HASTINGS, JANOFSKY, AND WALKER LLP /s/ Jeffrey G. Randall Jeffrey G. Randall Lead Attorney PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 1117 S. California Avenue Palo Alto, California 94304-1106 Telephone: (650) 320-1850 Facsimile: (650) 320-1950 firstname.lastname@example.org Allan M. Soobert PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 875 15th Street, N.W. Washington, DC 20005 Telephone: (202) 551-1822 Facsimile: (202) 551-0222 email@example.com S. Christian Platt PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 4747 Executive Dr., 12th Floor San Diego, CA 92121 Telephone: (858) 458-3034 Facsimile: (858) 458-3005 firstname.lastname@example.org Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: (903) 757-8449 Facsimile: (903) 758-7397 email@example.com COUNSEL FOR APPLE INC.
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was filed electronically in compliance with Local Rule CV-5 on this 16th day of June, 2010. As of this date, all counsel of record have consented to electronic service and are being served with a copy of this document through the Court's CM/ECF system under Local Rule CV-5(a)(3)(A). /s/ Jeffery G. Randall Jeffery G. Randall
LEGAL_US_E # 88548878.2