Netquote Inc. v. Byrd

Filing 199

Attachment 1
Proposed Pretrial Order by Plaintiff Netquote Inc.. (Attachments: # 1 Exhibit A-Plaintiff's Witness List, # 2 Exhibit B-Defendants' Witness List, # 3 Exhibit C-Joint Trial Exhibit List)(Perkins, Heather)

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Netquote Inc. v. Byrd Doc. 199 Att. 1 EXHIBIT A 1 Dockets.Justia.com Plaintiff' Witness List s Non-expert Will Call Witnesses Name and Summary of Testimony 1. Aaron Broome, Director of Sales & Service at NetQuote, Inc. Mr. Broome will testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations, including but not limited to, efforts to retain customers s victimized by Defendants' bogus leads. 2. Paul Ford, President at NetQuote, Inc. Mr. Ford will testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business s and operations, including but not limited to, discussions concerning stopping the cyber attack. 3. John Marosi, Director of Technical Operations at NetQuote, Inc. Mr. Marosi will testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations, including but not limited to, efforts to identify and stop the s cyber attack as well as NetQuote' sophisticated computer systems. s 4. Craig Shine, Vice President and Treasurer at NetQuote, Inc. Mr. Shine will testify regarding the subjects addressed in the testimony he provided during NetQuote' 30(b)(6) deposition and any s matter relating to NetQuote' business and operations, including but not limited to, results of the s cyber attack, personnel matters and personnel expenditures in relation to the cyber attack. 5. Scott Striegel, President Emeritus at NetQuote, Inc. Mr. Striegel will testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations, including but not limited to, its relationship with HSBC. s 6. Qin Zhou, Director of Software Development at NetQuote, Inc. Mr. Zhou will testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations, including but not limited to, efforts to identify and stop the s cyber attack as well as NetQuote' sophisticated computer systems. s Non-expert May Call Witnesses Name and Summary of Testimony 1. Marian Aavang, Executive Assistant & Customer Service Representative at NetQuote, Inc. Ms. Aavang may testify regarding any matter relating to attempts to access and the contents of e-mail accounts created by Brandon Byrd and data retrieved. 2. Mary Bro, President at CI Direct. Ms. Bro may testify regarding the subjects addressed in the testimony she provided during her deposition. 3. Brandon Byrd, employee at Mostchoice.com, Inc. Mr. Byrd may testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to the cyber attack. 4. Alberto Canas, Marketing Analyst at NetQuote, Inc. Mr. Canas may testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations, including but not limited to, NetQuote' on-line advertising s s 2 and NetQuote' affiliate relationships. s 5. Jeff Coppock, Vice President of National Sales at NetQuote, Inc. Mr. Coppock may testify regarding any matter relating to NetQuote' business and operations, including but not limited to, s its relationship with SBLI. 6. Cynthia Capozzi, Former Chief Information Officer for NetQuote, Inc. Ms. Capozzi may testify regarding the subjects addressed in the testimony she provided during her deposition. 7. Gregg Coccari, Chief Executive Officer at NetQuote, Inc. Mr. Coccari may testify regarding the subjects addressed in the testimony he provided during his deposition and any matter relating to NetQuote' business and operations. s 8. James H. Connors, III, Managing Director at Quist Valuation Company. Mr. Connors may testify regarding the basis for the analysis in the Allocation of the Purchase Price of NetQuote as of August 16, 2005 prepared by Quist Valuation. 9. Heather Delaney, Director of National Accounts at NetQuote, Inc. Ms. Delany may testify regarding the subjects addressed in the testimony she provided during her deposition and any matter relating to NetQuote' business and operations, including but not limited to, relationships s with national accounts. 10. Hussein Enan, Chief Executive Officer at InsWeb Corporation. Mr. Enan may testify regarding any matter relating to the on-line lead generation industry, including but not limited to, industry norms and competitive practices. 11. Martin Fleischmann, Chief Executive Officer, President and co-founder of Mostchoice.com, Inc. Mr. Fleischmann may testify regarding the subjects addressed in the testimony he provided during his deposition, and any matter relating to Mostchoice' business and operations, the cyber attack, s and corporate espionage aimed at NetQuote. 12. Amy Jensen, Project Manager, NetQuote, Inc. Ms. Jensen may testify regarding the subjects addressed in the testimony she provided during her deposition and any matter relating to NetQuote' business and operations, including but not limited to, marketing. s 13. Michael Levy, Chairman of Mostchoice.com, Inc. Mr. Levy may testify regarding the subjects addressed in the testimony he provided during Mostchoice.com, Inc.' 30(b)(6) deposition, and s any matter relating to Mostchoice' business and operations, the cyber attack, and corporate s espionage aimed at NetQuote. 14. Tim McTavish, Chief Executive Officer at Insureme. Mr. McTavish may testify regarding any matter relating to the on-line lead generation industry, including but not limited to, industry norms and competitive practices. 15. Mike Phillips, Former Programmer/Analyst at TechLaw Solutions. Mr. Phillips may testify regarding any matter relating to data analysis of NetQuote and Mostchoice' customer lists and s those results. 16. Sanjay Tiwary, Chief Information Officer at NetQuote, Inc. Mr. Tiwary may testify regarding NetQuote' business and operations, including but not limited to, NetQuote' computer information s s systems. 17. Shirley Villacis, Manager, Service Organization at NetQuote, Inc. Ms. Villacis may testify regarding any matter relating to NetQuote' business and operations, including but not limited to, s relationships with local accounts. 18. Danielle Wilkie, Marketing Director at NetQuote, Inc. Ms. Wilkie may testify regarding the subjects addressed in Ms. Jensen' deposition and any matter relating to NetQuote' business s s and operations, including but not limited to, marketing. 3 Deposition Testimony Name and Summary of Testimony 1. Michael Andrew, employee at Mostchoice.com, Inc. Mr. Andrew may testify regarding the subjects addressed in the testimony he provided during his deposition. 2. Mary Bro, President at CI Direct. Ms. Bro may testify regarding the subjects addressed in the testimony she provided during her deposition. 3. Brandon Byrd, employee at Mostchoice.com, Inc. Mr. Byrd may testify regarding the subjects addressed in the testimony he provided during his deposition any matter relating to the cyber attack. 4. Cynthia Capozzi, Former Chief Information Officer for NetQuote, Inc. Ms. Capozzi may testify regarding the subjects addressed in the testimony she provided during her deposition. 5. John Doria, Former Director of Strategic Planning at SBLI. Mr. Doria may testify regarding the subjects addressed in the testimony he provided during his deposition. 6. Martin Fleischmann, Chief Executive Officer, President, and co-founder of Mostchoice.com, Inc. Mr. Fleischmann may testify regarding the subjects addressed in the testimony he provided during his deposition, and any matter relating to Mostchoice' business and operations, the cyber s attack, and corporate espionage aimed at NetQuote. 7. Paul Goott, Director for Business Development and Marketing at HSBC. Mr. Goott may testify regarding the subjects addressed in the testimony he provided during his deposition. 8. Angilla Jones, employee at Mostchoice.com, Inc. Ms. Jones may testify regarding the subjects addressed in the testimony she provided during her deposition. 9. Mostchoice.com, Inc. Mostchoice' corporate representative may testify regarding the subjects s addressed in the testimony provided during the 30(b)(6) deposition. 10. Caroline Sellers, Operations Manager at Mostchoice.com, Inc. Ms. Sellers may testify regarding the subjects addressed in the testimony she provided during her deposition. 11. Erick Sullivan, Salesman at Mostchoice.com, Inc. Mr. Sullivan may testify regarding the subjects addressed in the testimony he provided during his deposition. Expert Testimony that Will be Presented Name and Summary of Testimony 1. Stephen A. Duree, CPA/ABV, CFE, MBA and Principal at Duree Barton, LLC. Mr. Duree will testify regarding any matter in his report and the subjects addressed in the testimony he provided during his deposition. Expert Deposition Testimony Name and Summary of Testimony 1. Mark Zyla, Managing Director at Acuitas, Inc. Mr. Zyla may testify regarding the subjects addressed in the testimony he provided during his deposition. 4

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