Free Witness List - District Court of Colorado - Colorado

Case 1:01-cv-01690-WDM-MJW

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Filed 11/28/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-WM-01690 (MJW) CONAIL CROSS, Plaintiff, v. THE HOME DEPOT Defendant. PLAINTIFF'S WITNESS LIST

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WITNESS LIST FORM Judge Walker D. Miller

Case No. 01-WM-1690

Date: December 5, 2005

Case Caption: Conail Cross v. The Home Depot Plaintiff's Witness List Will Call Witnesses Estimated Time for Examination Direct 1. Conail Cross: Discrimination at Home Depot since date of employment; Promises and representations of Home Depot employees, including Chuck Lempereur; Performance since date of employment; Comparative qualifications of assistant store managers who were promoted over Plaintiff; Defendant's promotion practices and policies; Damages-pecuniary, mental, emotional and physical; Employment History, Including Home Depot Representation of Plaintiff in Sexual Harassment Action 2. Jacqueline Cross: Wife of Plaintiff. Damages-pecuniary, mental, emotional and physical, including loss of consortium. 30 min. 20 min. 3 & ½ hrs. Cross 2 hrs.

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3. Hector Hernandez 6525 Oasis Butte Dr, Colorado Springs., 80918 Employment history, discriminatory and retaliatory practices

1 hr.

30 min.

of Home Depot and its employees, including Chuck Lempereur; Defendant's promotion practices and policies. 4. Daniel E. Friesen: How and when Defendant and its agents obtained Montgomery Ward and other materials and information regarding Plaintiff's prior employment history and prior discrimination claims and whether releases were obtained from Plaintiff. 15 min

5. Dr. Patricia Pacey: 6658 Gunpark Dr., Boulder, CO; Economic Damages

30 min.

20 min.

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Witnesses Who Will Appear By Deposition

5. Sherri Gibson McCune (California Resident) Discriminatory and retaliatory practices of Home Depot and its employees, including Chuck Lempereur;

45 min.

Comparative qualifications of assistant store managers who were promoted over Plaintiff; Promotion practices and succession planning. Employment History; Benefits.

6. Chuck Lempereur:

45 min.

Performance/employment history with Defendant, including discrimination and retaliation charges made as a result of his conduct; Promotion practices in Colorado and other areas where he worked; Succession planning: practice and procedure in Colorado; Persons promoted while he worked in Colorado; Review 9-Box Grids and performance evaluations and management tracking applications prepared while he was district manager; Comments showing racial bias; Promises and representations to Plaintiff re: Store Manager position; Defendant's employment practices and procedures; Problems at Store 1510 with employees, management and maintenance; District managers and store configuration; Employment history generally.
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7. Ron Whited:

25 min.

Company organization; Company rules contained in SOP's and handbooks; Promotion policies and practices and Succession planning: practice and procedure in Western States, Colorado and New-England area; Employment; History; Plaintiff's performance; Promotions in Colorado while he was District Manger; Employment History

8. Timothy Pfeiffer:

40 min.

Company organization; Company rules contained in SOP's and handbooks; Promotion policies and practices; Succession planning: practice and procedure in Colorado and western states; Conduct toward Plaintiff; Supervision of Lempereur; Involvement in succession planning and promotions as Regional Vice President; Polices re: bonuses, options and salary; Employment history.

9. Dr. Thomas Bartlett: Treating Physician: Disability and compensatory damages

40 min.

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10. Dr. Victor Neufeld: Treating Psychologist: Disability and compensatory damages 11. Dr. Richard Marciniak Treating physician: Disability and compensatory damages

30 min.

40 min.

DATED: November 23, 2005

s/William R. Hess WILLIAM R. HESS 5455 Wilshire Blvd. Suite 2100 Los Angeles, CA 90036 (323)931-7330 (fax)(323)931-7990 E-mail:[email protected] Attorney for Plaintiff

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE I hereby certify that on November 23, 2005 I electronically filed the foregoing Plaintiff's Proposed Jury Instructions with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses:

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Daniel Ernest Friesen [email protected] William R. Hess [email protected]

s/William R. Hess WILLIAM R. HESS 5455 Wilshire Blvd. Suite 2100 Los Angeles, CA 90036 (323)931-7330 (fax)(323)931-7990 E-mail:[email protected] Attorney for Plaintiff

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