LAMBERT v. HUSSEY-MAYFIELD MEMORIAL PUBLIC LIBRARY

Filing 21

Witness List Preliminary, filed by Plaintiff LAURA J. LAMBERT. (McMinn, Richard)

LAMBERT v. HUSSEY-MAYFIELD MEMORIAL PUBLIC LIBRARY

Doc. 21

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION LAURA J. LAMBERT Plaintiff, v. HUSSEY-MAYFIELD MEMORIAL PUBLIC LIBRARY, Defendant. ) ) ) ) ) CAUSE NO. 1:10-cv-0919-JMS-TAB ) ) ) ) )

PLAINTIFF'S PRELIMINARY WITNESS LIST Comes now the Plaintiff, Laura J. Lambert, by counsel, and pursuant to the Case Management Plan approved by the Court, hereby respectfully provides the following preliminary list of individuals who may be called as a witness to give testimony in this Cause. Plaintiff reserves the right to correct, clarify, supplement, or otherwise amend the following list of potential witnesses for any appropriate reason. 1. 2. Plaintiff Laura J. Lambert, Dr. Barbara Freeman, Ph.D. 1717 W. 86th Street, Suite 800N Indianapolis, Indiana 46260 Dr. Kimberly Gatzimos Zionsville, Indiana Ms. Martha Catt Ms. Shawn Parker Dr. Arthur Witham Health Services

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Dr. Presley Buntin Zionsville, Indiana Mary Rueff Virginia White Jamie Schlenk Susan Jenkins Lee Greaves Marilyn Martin Rick Deuschle Judy Bolinger Phyllis Robinson All individuals who participated in any actions affecting the terms and conditions of Plaintiff's employment, Any individual who replaced Plaintiff and/or assumed her duties and responsibilities upon her separation, Any person necessary for the foundation of documents, Any accounting/billing/other personnel of Defendant who can testify about Plaintiff's work hours, full-time benefits and pay rate, Any and all similarly situated individuals, Any person identified in any discovery answer or response or identified during the discovery process, Any individual necessary for impeachment or rebuttal purposes, Any individual identified on any witness list filed by Defendant, Any individual listed on parties' initial disclosures,

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Any expert or individual necessary to establish the value of the damages suffered by Plaintiff, Any expert or individual necessary to establish the disability of Plaintiff including, without limitation, all of her health care providers, All individuals responsible for the implementation and administration of Defendant's employment policies and procedures, All individuals who participated in actions concerning the termination of Plaintiff and the decision to terminate Plaintiff, All individuals who participated in events leading to the termination of Plaintiff, All individuals who participated in actions concerning the decision to retain Susan Jenkins, All individuals who investigated complaints of discrimination made by Plaintiff, All individuals who participated in decision concerning Plaintiff's request for reasonable accommodations, All individuals who participated in decision to terminate Plaintiff, All individuals who evaluated Plaintiff's work performance and the work performance of similarly situated individuals, Custodian of Defendant's records.

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Plaintiff reserves the right to correct, clarify, supplement, or otherwise amend the following list of potential witnesses for any appropriate reason.

Respectfully submitted,

/s/ Richard W. McMinn Richard W. McMinn, Attorney No. 13715-49 One of the Attorneys for Plaintiff

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CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and accurate copy of the foregoing document was electronically filed this 16th day of December, 2010. Parties may access this filing through the Court's electronic filing system. Notice of this filing will be sent to the following counsel of record by operation of the Court's system: Jane Ann Himsel Brian L. Mosby LITTLE MENDLESON, P.C. [e-mail] [e-mail]

/s/ Richard W. McMinn Richard W. McMinn HASKIN & LaRUE, LLP 255 North Alabama Street Second Floor Indianapolis, Indiana 46204-2131 Telephone: [phone] Facsimile: [phone] [e-mail]

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