Netquote Inc. v. Byrd

Filing 212

Netquote Inc. v. Byrd

Doc. 212 Att. 2

EXHIBIT B

Dockets.Justia.com

DEFENDANTS'WITNESS LIST Will Call Witness: 1. Michael Levy May Call Witnesses: 1. 2. 3. 4. Greg Coccari Craig Shine Paul Ford Heather Delaney Netquote CEO - familiar with Netquote liability/damages claims Netquote CFO - familiar with Netquote liability/damages claims Netquote President - familiar with Netquote liability/damages claims Netquote national accounts manager familiar with issues relating to national accounts E-mail Marketing Manager for Netquote Netquote local accounts customer service manager Netquote Director of Local Sales & Service familiar with receipt of Byrd leads Netquote former CIO - familiar with how Netquote handled lead blocking Netquote Technology Project Manager familiar with HSBC interface and submissions to Mostchoice Netquote Director of Technology Development familiar with Netquote lead database and filtering systems Netquote Director of Technology Operations familiar with Netquote lead filtering systems Netquote Affiliate Manager familiar with issues relating to affiliates Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Mostchoice CEO familiar with Mostchoice operations, click fraud, and lead industry Rebuttal Expert Witness familiar with the methods and calculations used by Netquote' expert (May testify by deposition) s necessary for impeachment necessary for rebuttal necessary for authentication of documents 1 Mostchoice chairman familiar with technology issues, Byrd project, click fraud and insurance and on-line lead generation industry

5. Danielle Wilkie 6. Shirley Villacis 7. Aaron Broome 8. Cynthia Capozzi 9. Amy Jensen 10. Quinn Zhou 11. John Marosi 12. Albert Cansas 13. John Kidd 14. Kevin Brumfiel 15. Jason Dummer 16. Martin Fleischmann 17. Mark Zyla 18. Any Witness 19. Any Witness 20. Any Witness

21. Any Witness

Listed by Netquote

Witnesses who may testify by deposition: 1. 2. 3. 4. Paul Goot John Doria Mary Bro Jeff Beck or Mark Gatch 5. Matt Goldberg 6. Donald Marquez 7. Will Smoltino 8. Chris Duncan 9. Kevin Nemec 10. Bob Vineyard 11. Jeff Beck or Mark Gatch 12. Scott Streigl 13. Stephen Duree 14. Caroline Sellers 15. Erick Sullivan HSBC Representative ­Relationship and Termination with Netquote Former SBLI employee ­Relationship and Termination with Netquote Responsible for running HSBC Call Center Representative of Ascencea, LLC - former Netquote customer familiar with Netquote lead quality Representative of Investors Financial Group -former Netquote customer familiar with Netquote lead quality Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar with why he left Netquote Local agent claimed by Netquote to have terminated because of Byrd's leads/familiar withwhy he left Netquote Former Netquote customer familiar with Netquote lead quality Former Netquote customer familiar with Netquote lead quality Netquote President Emeritus familiar with CI Direct and HSBC Netquote' expert witness as to causation re: local accounts and damages s Mostchoice operations manager familiar with Mostchoice operations Mostchoice salesman familiar with selling on-line insurance leads

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