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UNITED STATES DISTRICT COURT



EASTERN DISTRICT OF LOUISIANA


DANIEL S. SINCLAIR, JR.

V.

LEASE FINANCE GROUP, LLC A/K/A CIT
LEASE FINANCIAL GROUP, NATIONAL
ASSOCIATION OF CREDIT
MANAGEMENT (WESTERN MICHIGAN)
INC., PHILLIPS & COHEN ASSOCIATES,
LTD., EXPERIAN INFORMATION
SOLUTIONS, INC., TRANSUNION, LLC,
AND EQUIFAX CREDIT INFORMATION
SERVICES, INC.

CIVIL ACTION



NO. 07-1560



SECTION “B”: JUDGE LEMELLE



MAG. JUDGE KNOWLES

WITNESS AND EXHIBIT LISTS



ON BEHALF OF PHILLIPS & COHEN ASSOCIATES, LTD.



NOW INTO COURT, through undersigned counsel, comes defendant, PHILLIPS &

COHEN ASSOCIATES, LTD., who, in accordance with this Honorable Court’s Scheduling

Order dated July 22, 2008, hereby provides the following list of its may call witnesses and

exhibits it may introduce into evidence at the trial of this matter:

WITNESSES:

Robert H. Obringer
Phillips & Cohen Associates, Ltd.
258 Chapman Road, Suite 205
Newark, DE 19702

Representative of CIT Financial USA, Inc. f/k/a Lease Finance Group, LLC





Julie Allison
Lease Finance Group, LLC
233 North Michigan Avenue, Suite 1800
Chicago, IL 60601
Telephone (312) 980-5730





























Madeline Tabor
Lease Finance Group, LLC
233 North Michigan Avenue, Suite 1800
Chicago, IL 60601
Telephone (312) 980-5730

Ashley Grace
Phillips & Cohen Associates, Ltd.
258 Chapman Road, Suite 205
Newark, DE 19702

Brian Carscadden
Phillips & Cohen Associates, Ltd.
258 Chapman Road, Suite 205
Newark, DE 19702

Ross Enders
Phillips & Cohen Associates, Ltd.
258 Chapman Road, Suite 205
Newark, DE 19702

Matthew Phillips
Phillips & Cohen Associates, Ltd.
258 Chapman Road, Suite 205
Newark, DE 19702

Representatives of Central Progressive Bank;

Samuel Taggard;

Callin Sinclair;

Representatives of other banks or lenders not yet identified by plaintiff or in
discovery;

Mark Kullman;

Penn Clark;

Ronda Furlow;

Representatives of NACM;

Any and all witnesses to authenticate any document or exhibit;

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Any and all impeachment witnesses;

Any and all experts;

Any and all individuals identified during the course of discovery; and

Any and all individuals or experts called by any other party to this litigation.


EXHIBITS:



Screen print, transaction screen print, and notes regarding the subject matter from
Phillips & Cohen Associates, Ltd.;

Computer printout referencing three remittance invoices regarding payments made on
behalf of Louisiana Grill on November 20, 2000;

Partial computer printout regarding Phillips & Cohen’s check number 2070 issued on
December 1, 2000, to Lease Finance Group in the amount of $75,242.49;

“Agreement for the Collection of Unpaid Accounts” between Newcourt Financial and
Phillips & Cohen dated January 13, 1999;

All expert reports and copies of all materials relied upon by all experts in generating
opinions, verbally or in writing;

Deposition transcript of Daniel Sinclair, Jr. taken on February 10, 2009;

Deposition transcript of Central Progressive Bank taken on January 30, 2009;

All deposition transcripts of all depositions taken in this matter;

All documents relied upon by Ken Pickering, plaintiff’s expert;

All documents generated by Ken Pickering, plaintiff’s expert;

All documents received by Ken Pickering, plaintiff’s expert, regarding this matter;

All reports and drafts of reports by Ken Pickering, plaintiff’s expert;

Any and all contracts and/or leases;

Any and all credit reports;

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Any and all loan documents for plaintiff and/or businesses with which he is
associated;

Any and all insurance policies;

Any and all invoices;

Any and all cancelled checks;

Any and all correspondence between any and all parties as well as Experian, Equifax
and Transunion and non-parties that have been identified in discovery;

Any and all photographs, videotapes, diagrams and/or drawings;

Any and all statements;

Any and all pleadings;

Any and all impeachment evidence;

Any and all discovery requests and responses;

Any and all information received in response to any and all subpoenas for documents
issued in this matter;

Any and all affidavits;

Any and all documents produced by any party in initial disclosures; and

Any and all exhibits listed by any other party.

RESERVATION OF RIGHTS:



Defendant submits this may call witness and exhibit list in keeping with this Court’s

Scheduling Order. The deadlines ordered by this Court for defendants to produce expert

reports and materials in accordance with Rule 26, the discovery deadline, and the motion

deadlines all toll after the deadline for this may call witness and exhibit list. Discovery is

ongoing and much discovery remains to be conducted. Therefore, defendant, Phillips &

Cohen Associates, Ltd., reserves its right to clarify, elaborate upon, amend or supplement this

witness and exhibit list in keeping with this Court’s Orders.

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Respectfully submitted,

CRAWFORD LEWIS, P.L.L.C.

______/s/ Catherine S. Giering_____
KEELY Y. SCOTT (#23932)
CATHERINE S. GIERING (#26495)
450 Laurel Street, Suite 1600

Post Office Box 3656
Baton Rouge, Louisiana 70821-3656
Telephone: (225) 343-5290
Facsimile: (225) 383-5508

CERTIFICATE OF SERVICE








I HEREBY certify that on February 13, 2009, I electronically filed the foregoing with

the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing

to all counsel of record.







Baton Rouge, Louisiana, this 13th day of February, 2009.









/s/ Catherine S. Giering



G:\AIG\2032.018 Daniel Sinclair\pl\Witness-Exhibit Lists.2-13-09.doc

Counsel

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