Weather Underground, Incorporated v. Navigation Catalyst Systems, Incorporated et al

Filing 268

RESPONSE to 260 MOTION for Protective Order filed by Weather Underground, Incorporated. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I) (Schaefer, Enrico)

November 11, 2011

VIA EMAIL ONLY
William A. Delgado
Willenken Wilson Loh & Lieb LLP
707 Wilshire Boulevard, Suite 3850
Los Angeles, CA 90017
Re:

Trial Witness Issues

Dear Will:
As expected, this matter is going to trial. We have a lot of work to do in order to get ready.
For starters, please confirm that the following employees still work for Defendants and will
be available to appear at trial scheduled to begin March 12, 2012. To the extent that a
witness no longer works for Defendants, please indicate so, including the last known
address, phone numbers, and emails. To the extent the person still works for Defendants
but is unavailable, please identify the scheduling problem. To the extent the witness does
not work for Defendants but is voluntarily willing to appear, so indicate.
Finally, please confirm the availability of your experts, Richard Korf and John Berryhill, at
trial as well. While this may not be the final witness list for trial, this will at least give us a
head start in determining whom we might have to take de bene esse and who will be
appearing live.
Donald Misino
Mavi Llamas
Dennis Rhee
Chris Pirrone
Art Shaw
David Graff
Seth Jacoby
Lily Stevenson

November 11, 2011
Page 2 of 2

If you would like to provide me a list of the witnesses working for Plaintiff whom you intend
to call at trial, I will provide the same courtesy of indicating availability.
Sincerely,
TRAVERSE LEGAL, PLC

Enrico Schaefer
[e-mail]
ES/cad