Vargas et al v. Pfizer Inc. et al

Filing 97

PROPOSED PRETRIAL STATEMENT Plaintiffs' Joint Pre-Trial Order. Document filed by Ralph Vargas. (Attachments: # 1 Supplement Plaintiffs' Proposed Joint Pre-Trial Order# 2 Errata A to Plaintiffs' Joint Pre-Trial Order# 3 Exhibit B to Plaintiffs' Joint Pre-Trial Order# 4 Exhibit C to Plaintiffs' Joint Pre-Trial Order# 5 Affidavit Declaration of Paul Chin)(Chin, Paul)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

RALPH VARGAS and BLAND -

prepared by Ivan Rodriguez and produced during discovery bates stamped number 000033 6. The notes and drum transcriptions prepared by Matthew Ritter attached to his declaration as exhibit "B." The waveform graphs prepared by Ivan Rodriguez comparing BDG and Aparthenonia, which is attached to Ivan Rodriguez declaration. The graphs, charts and other documents comparing the frequency spectra of the first 2.3 second of drum music in Aparthenonia and BDG which is attached to the expert report of Dr. Steven Smith. Plaintiffs documents identified as bates stamped numbers 000003 and 000017, identifying the names of the distribution companies that distributed FD II and BDG. A copy of the recording BDG A copy of the recording Aparthenonia A copy of the recording of the Celebrex Commercial containing Aparthenonia A copy of all declarations and reports, including all the exhibits attached thereto, prepared by witnesses and experts for Defendants, except the second report by Dr. Richard Boulanger which was submitted after the close of discovery and as an exhibit to Defendants'second motion for summary judgment. Plaintiffs Second Amended Complaint Plaintiffs first set of interrogatories to Defendant Transeau

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Plaintiffs first demand for the production of documents and things to Defendant Transeau Plaintiffs first set of interrogatories to Defendant Transeau and responses thereto Plaintiffs first demand for the production of documents and things to Defendant Transeau and responses thereto Plaintiffs first set of interrogatories to Defendant EWC Plaintiffs first demand for the production of documents and things to Defendant EWS Plaintiffs first set of interrogatories to Defendant EWC and responses thereto Plaintiffs first demand for the production of documents and things to Defendant EWC and responses thereto Defendant Transeau' Answer to s Plaintiffs'Second Amended Complaint Defendant EWC Answer to Plaintiffs' Second Amended Complaint Initial Report of Dr. Steven Smith bates stamped numbers 000040, 000040A, 000040B Copy of e-mail written by Defendant Transeau identified as Plaintiffs Exhibit 6 from Defendant Transeau' deposition s and bates stamped numbers 000044, 000045, 000046, 000047 Deposition transcript of Defendant Brian Transeau taken on August 16, 2006. If necessary for impeachment.

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E-mail dated July 28, 2006 from Plaintiffs'counsel to Defendant BT' s attorneys (only if communications between attorneys is admissible by Court). E-mail dated August 7, 2006, 3:21 P.M., from Defendant BT' attorneys to s Plaintiffs'counsel (only if communications between attorneys is admissible by Court). E-mail dated August 7, 2006, 5:25 P.M., from Plaintiffs'counsel to Defendant BT' attorneys (only if communications s between attorneys is admissible by Court). E-mail dated August 7, 2006, 5:25 P.M., from Plaintiffs'counsel to Defendant BT' attorneys (only if communications s between attorneys is admissible by Court). Letter from Plaintiffs'counsel to Defendant BT' attorneys dated August s 15, 2006 (only if communications between attorneys is admissible by Court). Declaration of Anthony Ricigliano, and the exhibits attached thereto, dated Copy of compact disc identified as Exhibit D in the declaration of Ivan Rodriguez

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