Free Witness List - District Court of Federal Claims - federal

Case 1:00-cv-00755-FMA

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SOUTHERN COMFORT BUILDERS, ) INC., ) ) Plaintiff, ) No. 00-755C ) (Judge Allegra) v. ) ) THE UNITED STATES, ) ) Defendant.

PLAINTIFF'S WITNESS LIST Pursuant to this Court's Order dated Fegbruary 6, 2004, plaintiff provides the following list of witnesses that it may call on the trial of the within matter:

1.

Russ Allison, former project manager for SCBI. Mr. Allison may be contacted

through plaintiff's counsel. If called as a witness, Mr. Allison is expected to testify concerning the design deficiencies with respect to VFDs, UPS and grounding system issues, contract administration resulting in delays to the contractor's performance, and differing site conditions impacting SCBI's performance Telephone: 2. 321.449.3643 (Pager)

Mary Killgore, former project superintendent for SCBI. Ms. Killgore may be

contacted through plaintiff counsel. If called as a witness, Ms. Killgore is expected to testify concerning the design deficiencies with respect to VFDs, UPS and grounding

Case 1:00-cv-00755-FMA

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system issues,

contract administration resulting in delays to the contractor's

performance, and differing site conditions impacting SCBI's performance Telephone: 3. 95 E. Hall Rd Merritt Island, Fl 32953 D. R. Ellis through affidavit dated March 4, 2003. 321.449.8890

4.

William H. Butcher, president of Chrome Electric, Inc. Mr. Butcher may be

contacted at Chrome Electric, Inc. Telephone number 321.267.3253. Mr. Butcher is expected to testify concerning the design deficiencies with respect to VFDs, UPS and grounding system issues. Telephone: 321.267.0990 5. Jeffery Gillis, superintendent Chrome Electric, Inc. Mr. Gillis may be contacted

at Chrome Electric, Inc. Telephone number 321.267.0990. Mr. Gillis is expected to testify concerning the design deficiencies with respect to VFDs, UPS and grounding system issues. 6. Dofus Scott, One Contractor, Inc. (SCBI mechanical subcontractor). Mr. Scott

may be contacted through One Contractor, Inc. 321.382.1616. Mr. Scott is expected to testify concerning the VFD issue. 7. Albert Heredia, Merritt Island Air. Mr. Heredia may be contacted through

Mrerritt Island Air, 321.452.5665. Mr. Heredia is expected to testify concerning the VFD issue. 8. Michael Midgette, CPMG, LLC, construction Project Management Group, claims

consultants to SCBI. Mr. Midgette may be contacted through plaintiff's counsel. Mr.

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Midgette is expected to testify as to all aspects of plaintiff's claim entitlement and quantum of damages. Telephone: 850.622.0422 Plaintiff reserves the right to call as a witness at the time of trial any witness listed on defendant's witness list and to amend this list prior to trial. Submitted this 2nd day of March, 2004.

McManus & Graham, LLP s/ John C. McManus John C. McManus Attorneys for plaintiff Of Counsel: J. Hatcher Graham P.O. Box 95269 Atlanta, Georgia 30347 Tel: 404.929.9122 Fax: 404.929.0370

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CERTIFICATE OF SERVICE This is to certify that I have this day served opposing counsel with a copy of the foregoing pleading via facsimile, U. S. First Class Mail, postage prepaid, properly addressed to: David R. Feniger, Esq. Commercial Litigation Branch Civil Division, Department of Justice Room 11066 1100 L Street, N.W. Classification Unit 8th Floor Washington, D.C. 20530 This 2nd day of March 2004.

McMANUS & GRAHAM, LLP /John C. McManus John C. McManus D.C. Bar No. 385585 Attorney for Southern Comfort Builders, Inc.

P.O. Box 95269 Atlanta, Georgia 30347 Tel: 404.929.9122