Deliverance Poker, LLC v. Tiltware, LLC et al

Filing 86

REPLY to Response to Motion, filed by Tiltware, LLC, re 67 MOTION to Continue Trial Date and Discovery Cutoff or Bifurcate or Sever Claims Against Tiltware MOTION to Bifurcate filed by Defendant Tiltware, LLC (Attachments: # 1 Exhibit)(Bessette, Paul)

Deliverance Poker, LLC v. Tiltware, LLC et al

Doc. 86 Att. 1

EXHIBIT A

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION DELIVERANCE POKER, LLC, Plaintiff v. CIVIL ACTION NO. 1:10-CV-00664-JRN

MICHAEL MIZRACHI and TILTWARE, LLC, Defendant PLAINTIFF'S SECOND SUPPLMENTAL DISCLOSURES Plaintiff Deliverance Poker, LLC submits the following second supplemental disclosures under Federal Rule of Civil Procedure 26, Respectfully submitted, By: Is/ Douglas M. Becker Douglas M. Becker Texas State Bar No. 02012900 John D. Jacks Texas State Bar No. 00785986 GRAY & BECKER, P.C. 900 West Avenue Austin, Texas 78701 Telephone: [phone] Facsimile: [phone] COUNSEL FOR PLAINTIFF DELIVERANCE POKER, LLC

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PLAINTIFF'S SECOND SUPPLEMENTAL DISCLOSURES (i) The name and, if known, the address and telephone number of each individual likely to have discoverable information--along with the subjects of that information--that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment. Aaron Copeland Stuart Catlin Efren Sal divar The Denim Group 3463 Magic Drive, Suite 315 San Antonio, Texas 78229 [phone] Individuals with knowledge of evaluation of RealDeck software. (ii) A copy--or a description by category and location--of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment. Plaintiff previously provided documents Bates numbered DP00001 to DP000436, plus the link to the following website: http://dernos.thisisboss.cornidp/intro . In addition, Plaintiff provides documents Bates numbered DP000437 to DP001035. (iii) A computation of each category of damages claimed by the disclosing party--who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered. In addition, to Plaintiffs Initial Disclosures, Plaintiff also previously provided the written report of Gary Wilcox, Ph.D., with his supporting materials. See DP000162 to DP00324.

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CERTIFICATE OF SERVICE
I certify that on 3/14/2011, a true and correct copy of Plaintiff's Second Supplemental Initial Disclosures was eraailed and faxed to the following counsel: John P. Henry The Law Offices of John Henry, P.C. 407 West Liberty Avenue Round Rock, TX 78664 Ian J. Imrich 10866 Wilshire Blvd., Suite 1240 Los Angeles, California 90024 Paul R. Bessette R. Adam Swick Greenberg Traurig, LLP 300 W. 6 St., Suite 2020 Austin, Texas 78701 George Belfield Greenberg Traurig, LLP 300 West Sixth Street, Suite 2020 Austin, Texas 78701 Jordan Grotzinger Greenberg Traurig, LLP 300 West Sixth Street, Suite 2020 Austin, Texas 78701

/s/ John D. Jacks John D. Jacks

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