Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 29

NOTICE by Jayme Gordon PLAINTIFFS LIST OF PROPOSED DEPONENTS (Madera, Gregory)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
JAYME GORDON,
Plaintiff,
C.A. No. 1:11-cv-10255-JLT

v.
DREAMWORKS ANIMATION SKG, INC.,
DREAMWORKS ANIMATION LLC, and
PARAMOUNT PICTURES, CORP.,
Defendants.

PLAINTIFF’S LIST OF PROPOSED DEPONENTS
Pursuant to the Modified Discovery Order and Notice of Scheduling Order, Plaintiff
Jayme Gordon hereby identifies the following people whom Plaintiff may notice for deposition.
DEPONENT
1.

NICOLAS MARLET: Illustrator and character designer for DreamWorks; creation and
development of the characters featured in Defendants’ Kung Fu Panda movies

2.

MICHAEL LACHANCE: Former Development Executive of DreamWorks; creation and
development of Defendants’ Kung Fu Panda story, characters, and movies

3.

CYRUS VORIS: Writer for DreamWorks; creation and development of Defendants’ Kung Fu
Panda story, characters, and movies

4.

ETHAN REIF: Writer for DreamWorks; creation and development of Defendants’ Kung Fu
Panda story, characters, and movies

5.

MARK OSBORNE: Director for DreamWorks; creation and development of Defendants’
Kung Fu Panda story, characters, and movies

6.

JOHN STEVENSON: Director for DreamWorks; creation and development of Defendants’
Kung Fu Panda story, characters, and movies

DEPONENT
7.

JONATHAN ABEL: Screenplay writer for DreamWorks; creation and development of
Defendants’ Kung Fu Panda story, characters, and movies

8.

GLENN BERGER: Screenplay writer for DreamWorks; creation and development of
Defendants’ Kung Fu Panda story, characters, and movies

9.

CHRIS KUSER: Development Executive for DreamWorks; creation and development of
Defendants’ Kung Fu Panda story, characters, and movies

10.

RAPHE BECK: Former staff writer for DreamWorks; origin of Defendants’ Kung Fu Panda
story and characters

11.

KATE SWANBORG: DreamWorks Executive; writer; origin of Defendants’ Kung Fu Panda
story and characters

12.

LANCE YOUNG: Former employee of DreamWorks; creation and development of
Defendants’ Kung Fu Panda story, characters, and movies

13.

ERIC SWANBORG: Writer; production manager; origin of Defendants’ Kung Fu Panda
story and characters

14.

MICHAEL EISNER: Former Chief Executive Office, The Walt Disney Co.; request for,
submission of, and knowledge of Plaintiff’s works

15.

SHARON EISEN: Former employee, The Walt Disney Co.; request for, submission of, and
knowledge of Plaintiff’s works

16.

JEFFREY KATZENBERG: Chief Executive Office, DreamWorks; creation and
development of Defendants’ Kung Fu Panda story, characters, and movies; submission and
knowledge of Plaintiff’s works

17.

RICH SULLIVAN: Head of Corporate Finance, DreamWorks; Defendants’ revenue and
profits; damages

18.

BILL DAMASCHKE: Executive Producer / Chief Creative Officer, DreamWorks; creation
and development of Defendants’ Kung Fu Panda story, characters, and movies

19.

MELISSA COBB: Producer, DreamWorks; creation and development of Defendants’ Kung
Fu Panda story, characters, and movies

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DEPONENT
20.

TIM PERRY: Former research employee, DreamWorks; creation and development of
Defendants’ Kung Fu Panda story, characters, and movies

21.

KENNETH PARTELLO: Illustrator; creation and development of Plaintiff’s works

22.

EMILY BLUMSACK: Acquaintance of Plaintiff; submission and knowledge of Plaintiff’s
works

23.

ANDREW BLUMSACK: Related to Emily; formerly affiliated with DreamWorks;
submission and knowledge of Plaintiff’s works

24.

DIANE KORO: Former web-developer for Plaintiff; development of Plaintiff’s websites and
works

25.

PATRICIA M. BOYDEN: Former assistant for Plaintiff; creation and development of
Plaintiff’s works; submission of Plaintiff’s materials

26.

CORPORATE WITNESSES OF DEFENDANTS

27.

EXPERT WITNESSES OF DEFENDANTS

Plaintiff respectfully reserves the right to expand or modify this list based on further
information revealed as discovery continues, including any persons identified by Defendants as
having relevant knowledge.

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Dated: June 30, 2011

/s/ Gregory A. Madera
Gregory A. Madera, BBO #313,020
Thomas A. Brown, BBO #657,715
Maureen M. Brenner, BBO #679,573
FISH & RICHARDSON P.C.
One Marina Park Drive
Boston, MA 02210-1878
[phone]
[e-mail]; [e-mail];
[e-mail]
Mark A. Fischer, BBO #167,100
DUANE MORRIS LLP
470 Atlantic Avenue, Suite 500
Boston, MA 02210-2243
[phone]
[e-mail]
Juanita R. Brooks, pro hac vice
FISH & RICHARDSON P.C.
12390 El Camino Real
San Diego, CA 92130
[phone]
[e-mail]
Michael J. Kane, pro hac vice
Joel D. Leviton, pro hac vice
FISH & RICHARDSON P.C.
3200 RBC Plaza
60 South Sixth Street
Minneapolis, MN 55402
[phone]
[e-mail]
[e-mail]
Kristen McCallion, pro hac vice
FISH & RICHARDSON P.C.
601 Lexington Avenue, 52nd Floor
New York, NY 10022
[phone]
[e-mail]
ATTORNEYS FOR PLAINTIFF
JAYME GORDON

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CERTIFICATE OF SERVICE
I hereby certify that this document(s) filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and paper copies will be sent to those indicated as non-registered participants on this 30th day of
June, 2011.
/s/ Gregory A. Madera
Gregory A. Madera
60710684.doc

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