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United States District Court for the District of Colorado
Civil Action File No. THE ESTATE OF CHANDA JOHNSON, Deceased by DORRIS RICHARDSON, Personal Representative, Plaintiff, V. AVAYA COMMUNICATION, INC. A Delaware Corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) 04-cv-01825-ZLB-BNB
PLAINTIFF'S AMENDED WITNESS AND EXHIBIT LIST FOR JANUARY 17, 2006 HEARING
COMES NOW Dorris Richardson, Personal Representative of the Estate of Chanda Johnson, by and through her attorney Larry Carroll of the Law Office of Larry Carroll, P.C. and submits an Amended Witness and Exhibit List for the January 17, 2006 Hearing, the only difference from the previously submitted Witness and Exhibit List for the January 17, 2006 Hearing being the change of the name Jacqueline Fitchenor to Jackie Anderson because our office had the wrong name listed, and submits the Witness and Exhibit List for the January 17, 2006 Hearing as follows: WITNESSES 1. That Plaintiff endorses all witness submitted by Defendant. 2. That Dorris Richardson may be called a witness and is expected to testify as to her knowledge regarding the Estate of Chanda Johnson and Settlement issues and concerns. 3. That Elonca Richardson and Mychel Richardson may be called as witnesses and are expected to testify as to what they remember their mother saying regarding her position and job dispute with Avaya, Inc. They are expected to testify in person. 4. That Jackie Anderson may be called as a witness and is expected to testify to goings-on at Avaya, Inc. 5. That Defendant alleges to have an e-mail withdrawing the $4792.80 Offer of Settlement to CWA Local 777, which has never been received by Plaintiff or her counsel.
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6. Any witness necessary for impeachment, rebuttal or sur-rebuttal may testify in person. EXHIBITS 1. That Plaintiff endorses all exhibits submitted by Defendant. 2. E-Mail from Susan Earhart to Dawn Barraco, one dated February 28, 2002 and one dated March 19, 2002 (both on same document) regarding Settlement Proposal and Denial of Second Step Grievance due to CWA Local 777 not signing and returning Settlement Agreement and Release. 3. Settlement Agreement and Release for Grievance No. 01-0831 with settlement offer of $4972.80. 4. Handwritten Correspondence between Susan Earhart and Dawn Barraco regarding settlement agreement. 5. Any document/exhibit necessary for impeachment, rebuttal or sur-rebuttal.
Respectfully Submitted this 13th day of January 2006. Original signatures on file at the Law Office of Larry Carroll, P.C. /s/ Larry Carroll Larry Carroll # 3028 Attorney for Personal Representative 1900 Grant St., Ste. 650 Denver, CO 80203 720-377-0135
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CERTIFICATE OF MAILING I, the undersigned, herby certify that on the 13th day of January 2006 I e-filed via CMECF U.S. District Court/PACER and/or delivered a true and correct copy of the foregoing PLAINTIFF'S WITNESS AND EXHIBIT LIST FOR JANUARY 17, 2006 HEARING via the U.S. Mail, postage prepaid and addressed to the following: Patrick J. Miller SHERMAN & HOWARD, L.L.C. DC BOX 12 663 Seventeenth Street, Suite 3000 Denver, CO 80202 Tel: (303) 297-2900 Fax: (303) 298-0940
Original signature on file at the Law Office of Larry Carroll, P.C. /s/ Angela Bender______________ Angela Bender, Paralegal