Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1244

Proposed Pretrial Order by Eolas Technologies Incorporated, The Regents of the University of California. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27)(McKool, Mike) Modified on 1/17/2012 (mjc, ). Modified on 1/17/2012 (mjc, ).

EXHIBIT 8

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
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Eolas Technologies Incorporated,

Plaintiff,
v.
Adobe Systems Incorporated et al

Defendants.

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Civil Action No. 6:09-cv-446
Jury Demanded

DEFENDANT STAPLES, INC.’S WITNESS LIST
COMES NOW defendant and counterclaim plaintiff Staples Incorporated (“Staples”),
and files its Trial Witness List and hereby identifies the following trial witnesses whom Staples
will or may call to testify before the jury during the trial commencing October 11, 2011.
I. WITNESSES STAPLES WILL CALL
Staples will call the following witnesses live to testify before the jury at the trial of this
matter:
•

Michael Doyle;

•

Nicholas Godici;

•

Richard Phillips;

•

Brian Tilzer;

•

Adam Candela;

•

Adam Chace;

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•

Steve Gribble; and

•

Julie L. Davis.
Staples reserves the right to supplement its Trial Witness List as allowed by law.
II. WITNESSES STAPLES MAY CALL
Staples may call the following witnesses live to testify before the jury at the trial of this

matter:
•

David Mastovsky;

•

Benjamin Peck;

•

Thomas Tobin;

•

Mark Connolly;

•

Karyn King;

•

Robert Vareschi;

•

Carrie Bourke;

•

Kavita Baball;

•

Scott Zakrajsek;

•

Anabela Perozek;

•

Cheong S. Ang;

•

David C. Martin;

•

Charles E. Krueger;

•

Marc Andreessen;

•

Eric Bina;

•

Tim Berners-Lee;

•

John Cahill;

•

Dale P. Dougherty;

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•

Alicia Gackle;

•

Brandy Hernandez;

•

Jim Stetson;

•

George Toye;

•

Karl A. Jacob;

•

Tony Johnson;

•

Bill Janssen;

•

Charles Kulas;

•

Dave Raggett;

•

Scott Silvey;

•

Mark Swords;

•

Danny Goodman;

•

Joseph Hardin;

•

Pei-Yuan “Perry” Wei;

•

Terry Winograd; and

•

Michael Woods.
Staples reserves the right to supplement its Trial Witness List as allowed by law.
III. WITNESSES STAPLES EXPECTS TO PRESENT BY DEPOSITION
Staples may call by deposition each and every Eolas or third-party witness deposed by

defendants during discovery. Staples may also call by deposition Staples witnesses who have
been or may be deposed.
Staples notes that not all noticed depositions have occurred as of this date, and
specifically reserves the right to supplement its Trial Witness List accordingly. Staples further
reserves the right to supplement its Trial Witness List as allowed by law.

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Date: August 12, 2011

/s/ Kate Hutchins
Michael E. Richardson (TX Bar No.
24002838)
[e-mail]
Beck Redden & Secrest
1221 McKinney, Suite 4500
Houston, TX 77010
Telephone: [phone]
Facsimile: [phone]
Mark G. Matuschak (admitted pro hac vice)
[e-mail]
Donald R. Steinberg (admitted pro hac vice)
[e-mail]
Wilmer Cutler Pickering
Hale and Dorr LLP
60 State Street
Boston , MA 02109
Telephone: [phone]
Facsimile: [phone]
Kate Hutchins (admitted pro hac vice)
[e-mail]
Wilmer Cutler Pickering
Hale and Dorr LLP
399 Park Avenue
New York, NY 10022
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR DEFENDANT
STAPLES, INC.

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CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was served on all counsel of
record by e-mail on this the 12th day of August, 2011.
/s/ Richard Ewenstein
Richard Ewenstein

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