Free Proposed Pretrial Order - District Court of Colorado - Colorado

Case 1:01-cv-02324-JLK-MEH

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge John L. Kane Civil Action No. 01-cv-2324-JLK-MEH CHARLES T. GREEN, PHILLIP R. WENTLAND and MARILYN BREITHAUPT, Plaintiffs, vs. SEARS, ROEBUCK & CO., a New York corporation, Defendant.

DEFENDANT'S PROPOSED WITNESS LIST

(1) 1.

Defendant's witnesses who will be present at trial:

Charles T. Green. Address and phone number are known to the Plaintiffs.

This witness will testify in person concerning the allegations in his Complaint as well as any matter covered in his deposition, any witness statement or affidavits, if any, which items shall constitute a supplement to these disclosures. 2. Phillip R. Wentland. Address and phone number are known to the

Plaintiffs. This witness will testify in person concerning the allegations in his Complaint as well as any matter covered in his deposition, any witness statement or affidavits, if any, which items shall constitute a supplement to these disclosures. 3. Marilyn Breithaupt. Address and phone number are known to the Plaintiffs.

This witness will testify in person concerning the allegations in her Complaint as well as

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any matter covered in her deposition, any witness statement or affidavits, if any, which items shall constitute a supplement to these disclosures. 4. Stephanie Brooks, Service Unit Manager, Sears, Roebuck and Co. This

witness will testify in person concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; interview process for each of the applicants, including Plaintiffs; position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavits, if any. (2) Defendant's witnesses who may be present at trial if the need arises: 1. Frank Mufic, Manager, Sears, Roebuck and Co. This witness will testify in

person concerning the history/background of Sears, Roebuck and Co.; the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who

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would be retained and who would be terminated during late 1999 and early 2000; position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 2. Daniel Perry, Project Manager, Sears, Roebuck and Co. This witness will

testify in person concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's depositions, witness statements or affidavits, if

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any. 3. Nancy Savard, Project Manager, Sears, Roebuck and Co. This witness will

testify in person concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; Interview process for each of the applicants, including Plaintiffs; position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's depositions, witness statements or affidavits, if any. 4. Steven Courier, Project Manager, Sears, Roebuck and Co. This witness

will testify in person concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills for needed to fill the

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technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 5. Robert Garcia, Sears, Roebuck and Co. This witness will testify in person

concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named Plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 6. Kelli Fanning, Human Resources Department, Sears, Roebuck and Co.

This witness will testify in person concerning the reasons behind Sears' decision to

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redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; the guidelines incorporated in implementing this redesign process and determining who would be retained and who would be terminated during late 1999 and early 2000; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills for needed to fill the technician positions at the new facility; Plaintiffs' duties, responsibilities, capabilities, and performance; the accuracy of the factual allegations raised by each of the named plaintiffs in the Complaint; the circumstances surrounding the termination of employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in these individuals' depositions, witness statements or affidavits, if any. 7. Ray Figueroa, Technical Manager, and Plaintiff Phillip Wentland's former

supervisor, Sears, Roebuck and Co. This individual may testify concerning Plaintiff Wentland's duties, responsibilities, capabilities, and performance at the Thornton facility; discussions with Wentland regarding the elimination of his position at the Thornton facility, applying for a position at the Aurora facility and Wentland's plans for retirement; the accuracy of the factual allegations raised by Wentland in the Complaint; the circumstances surrounding the termination of Wentland's employment with Sears; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this

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individual's deposition, witness statement or affidavit, if any.

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8.

Craig Peterson, Technical Manager, and Plaintiff Charles Green's former

supervisor, Sears, Roebuck and Co. This individual may testify concerning Plaintiff Green's duties, responsibilities, capabilities, and performance at the Thornton facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 9. Marty Templin, former Technical Manager and former supervisor of

Plaintiffs Marilyn Breithaupt and Phillip Wentland at Sears, Roebuck and Co. This individual may testify concerning Plaintiff Wentland's duties, responsibilities, capabilities, and performance at the Thornton facility; Wentland's plans for retirement; Plaintiff Breithaupt's duties, responsibilities, capabilities, and performance at the Thornton facility; position requirements/skills needed to fill the technician positions at the new facility and whether Breithaupt's skills and abilities would fit these needs; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 10. Virginia Ballou, former Team Leader of Electronics & Mechanical Shop

TV/VCR Combination at Sears, Roebuck and Co.'s Aurora Unit. This individual may testify concerning position requirements/skills needed to fill the positions at the new facility; interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of

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employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 11. Gunther Beckman, Line Specialist 2, Carry-In Electronics Audio at Sears,

Roebuck and Co.'s Denver outlet store. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 12. Dave Bunton, Service Technician at Sears, Roebuck and Co.'s Denver

outlet store. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 13. Carol Dobbins, former Mechanical Technician at Sears, Roebuck and Co.

This individual may testify concerning the position requirements/skills needed to fill the positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this

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individual's deposition, witness statement or affidavit, if any. 14. Greg Fleisher, In-Home Refrigeration Technician at Sears, Roebuck and

Co.'s Thornton Unit. This individual may testify concerning Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 15. Stan Kossman, Line Specialist 2, Carry-In Mechanical Floor Care

department at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 16. Josie Padilla, Line Specialist 2, Carry-In Mechanical Sewing department at

Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any.

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17.

Wanda Reavis, Line Specialist 2, Carry-In Mechanical Sewing department

at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 18. Rich Schley, Line Specialist 1, Carry-In Small Gas Engine in Lawn &

Garden department at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 19. Randy Shioshita, former associate at Sears, Roebuck and Co. This

individual may testify concerning Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 20. Craig Slabodnik, former Service Technician 2, Shop Mechanical General at

Sears, Roebuck and Co.'s Thornton Unit. This individual may testify concerning the

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position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 21. Jack Stear, former Line Specialist 2 Shop Mechanical General, at Sears,

Roebuck and Co.'s Thornton Unit. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 22. Curtis McReynolds, former Levell III Electronics Technician, at Sears,

Roebuck and Co.'s Thornton Unit. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 23. John Trujillo, Service Technician, Lawn & Garden department, at Sears,

Roebuck and Co.'s Aurora Unit. This individual may testify concerning the position

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requirements/skills needed to fill the positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 24. Walter Shetskie, Line Specialist 2, Lawn & Garden department, at Sears,

Roebuck and Co.'s Aurora Unit. This individual may testify concerning the position requirements/skills needed to fill the positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 25. Frank Weinzapfel, Line Specialist 2, Carry-In Electrical TV repair

department, at Sears, Roebuck and Co.'s Aurora Unit. This individual may testify concerning the position requirements/skills needed to fill the positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 26. Johnny Clemons, former Shipper/Receiver, Parts Shipping/Receiving, at

Sears, Roebuck and Co.'s Aurora Unit. This individual may testify concerning the

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position requirements/skills needed to fill the positions at the new facility; the interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 27. Dale Manwearing, Parts Clerk at Sears, Roebuck and Co.'s Aurora Unit.

This individual may testify concerning Sears' anti-discrimination policy and other relevant personnel policies; any matter covered in this individual's deposition, witness statement or affidavit, if any. 28. James Blankenship, Line Specialist 2 Carry-In Electronics TV department

at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 29. Raymond Ayearst, Line Specialist 1, Carry-In Large and Small Gas Engine

in Lawn & Garden department at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of

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employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 30. Kristopher Dean, Line Specialist 2, Floor Care department at Sears,

Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 31. Nathan Trosper, Line Specialist 1, Carry-In Large and Small Gas Engine in

Lawn & Garden department at Sears, Roebuck and Co.'s Aurora facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the interview process for new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 32. Steven Bettis, Electronics Technician III at Sears, Roebuck and Co.'s

Thornton facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the application and interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or

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affidavit, if any. 33. Norbert Spenner, Electronics Technician III at Sears, Roebuck and Co.'s

Thornton facility. This individual may testify concerning the position requirements/skills needed to fill the technical positions at the new facility; the application and interview process for new facility or alternative position; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 34. Starry Carter, Transactions Service Department at Sears, Roebuck and Co.

This individual may testify concerning the procedures involved in preparation of initial information packages for all employees affected by November 1999- early 2000 redesign process; the procedures involved in preparation of severance packages; steps taken to abide by OWBPA regulations during redesign process; Sears' anti-discrimination policy and other relevant personnel policies; any matter covered in this individual's deposition, witness statement or affidavit, if any. 35. Ron Medford, Region Manager, Carry-In, Sears, Roebuck and Co. This

individual may testify concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; his duties/responsibilities as National Operations Manager and supervisor of the redesign team; the guidelines incorporated in implementing the redesign process during late 1999 and early 2000; the

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interview process for each of the applicants, including Plaintiffs; the position requirements/skills needed to fill the technician positions at the new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 36. Chuck Nash, National Sales Manager, Sears, Roebuck and Co. This

individual is may testify concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; his duties/responsibilities as National Redesign lead and supervisor of Ron Medford and the redesign team; the guidelines incorporated in implementing the redesign process during late 1999 and early 2000; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills needed to fill the technician positions at the new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 37. Mark Suret, Regional Human Resources Director, Sears, Roebuck and Co.

This individual may testify concerning the reasons behind Sears' decision to redesign its appliance repair process for shop technicians in late 1999 and early 2000; the development of Sears' redesign process for shop technicians; his duties/responsibilities as Regional Human Resources Director and supervisor of Kelli Fanning; the guidelines

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incorporated in implementing the redesign process during late 1999 and early 2000; the individual meetings held with each associate whose job was affected by the redesign and the information covered in each of these meetings, including the releases signed by associates who were not offered positions at the Aurora facility; the interview process for each of the applicants, including Plaintiffs; the position requirements/skills for needed to fill the technician positions at the new facility; Sears' anti-discrimination policy and other relevant personnel policies; Sears' treatment of employees who are similarly situated with named Plaintiffs; any matter covered in this individual's deposition, witness statement or affidavit, if any. 38. 39. Any witnesses necessary to lay a foundation for summary exhibits. Any witness necessary for rebuttal or impeachment.

(3) Defendant's Witnesses where testimony is expected to be presented by means of a deposition or Affidavit: 1. 2. 3. Charles T. Green Phillip R. Wentland Marilyn Breithaupt Defendant's Experts (1) None. (2) 1. Defendant's expert witnesses who may be present at trial: Bonnie Ruth, a vocational specialist may testify as to her vocational Defendant's expert witnesses who will be present at trial:

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evaluation of Plaintiffs, job market and job availability, rebuttal of Plaintiffs' expert conclusions and opinions, and other matters set forth in her reports. 2. Scott Saltzman, an economic specialist who may testify as to Plaintiffs'

economic losses as a result of their employment separation, rebuttal of Plaintiffs' expert conclusions and opinions, and other matters set forth in his report. (3) deposition: 1. Jane H. Lillydahl, an economist who may testify as to Plaintiffs' economic Expert witnesses where testimony may be presented by means of a

losses as a result of their termination from Defendant.