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IN THE UNITED STATES DISTRICT COURT



FOR THE EASTERN DISTRICT OF LOUISIANA




DANIEL SINCLAIR, JR.

VS.

LEASE FINANCE GROUP, LLC AKA
CIT LEASE FINANCIAL GROUP,
NATIONAL ASSOCIATION OF CREDIT
MANAGEMENT (WESTERN MICHIGAN),
INC., AND PHILLIPS & COHEN ASSOCIATES,
LTD.




















CIVIL ACTION NO. 2:07cv1560-ILRL-DEK





PLAINTIFF

DEFENDANTS

PLAINTIFF’S WITNESS AND EXHIBIT LIST





Plaintiff Daniel Sinclair, Jr. submits this witness and exhibit list pursuant to the Court’s

scheduling order. Because ongoing discovery may reveal witnesses and exhibits not identified

herein, Plaintiff reserves the right to supplement and/or amend its witness and exhibit list.

WITNESS LIST

(1) Daniel Sinclair

(2)

Samuel Taggard

(3)

Callan Sinclair

(4)

Cayman Sinclair

(5)

Penn Clark

(6) Marc Kullman

(7)

Rhonda Furlow

(8)

Ashley Grace

(9)

Kenneth Pickering

(10) Nicole Tooks, Financial Services Resolution Specialist, Better Business Bureau, 330 N.

Wabash, Suite 2006, Chicago, IL 60611



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(11) Any and all officers, agents, servants and employees of CIT Lease Financial Group, a/k/a

Lease Finance Group, LLC, involved in handling the accounts for commercial equipment leases

guaranteed by Daniel Sinclair for Louisiana Grill, including but not limited to:

Madeline Tabor

Sam Buono

(12) Any and all officers, agents, servants and employees of Phillips & Cohen Associates,

involved in handling the accounts for commercial equipment leases maintained by Lease Finance

Group, LLC and guaranteed by Daniel Sinclair for Louisiana Grill, including but not limited to:

Ross S. Enders, Phillips & Cohen, 695 Rancocas Road, Westampton, NJ 08060

Brian Carscadden, Phillips & Cohen, 695 Rancocas Road, Westampton, NJ 08060

Matthew M. Phillips, Phillips & Cohen, 695 Rancocas Road, Westampton, NJ 08060

(13) Any and all officers, agents, servants and employees of National Association of Credit

Management (Western Michigan), Inc., involved in handling the accounts for commercial

equipment leases guaranteed by Daniel Sinclair for Louisiana Grill, which were referred to it by

Lease Finance Group, LLC, including but not limited to:

Ashley Bravata, 3959 Clay Avenue SW, Wyoming, MI 49548-3014

Mary Jamerson, 3959 Clay Avenue SW, Wyoming, MI 49548-3014

Kim Natte, 3959 Clay Avenue SW, Wyoming, MI 49548-3014

Kelly Gaines, 233 N. Michigan Ave., Suite 1800, Chicago, IL 60601

(14) Any and all officers, agents, servants and employees of Experian Information Solutions,

Inc., involved in handling credit information related to accounts for commercial equipment

leases with Lease Finance Group, LLC, guaranteed by Daniel Sinclair for Louisiana Grill

(15) Any and all officers, agents, servants and employees of TransUnion, LLC involved in



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handling credit information related to accounts for commercial equipment leases with Lease

Finance Group, LLC, guaranteed by Daniel Sinclair for Louisiana Grill

(16) Any and all officers, agents, servants and employees of Equifax Credit Information

Services, Inc., involved in handling credit information related to accounts for commercial

equipment leases with Lease Finance Group, LLC, guaranteed by Daniel Sinclair for Louisiana

Grill

(17)

Representatives or officers of any other party, the necessity of whose testimony may

become apparent as discovery progresses

(18) Any other person identified or called by any other party

(19) Any other person identified through discovery including, but not limited to any fact

witness or expert

Plaintiff reserves the right to supplement and/or amend this witness list as discovery

proceeds.

EXHIBIT LIST

(1)

October 26, 2000 correspondence from Samuel C. Taggard to Ashley Grace

(2)

Copy of Louisiana Grill check # 4130 paid to Phillips & Cohen in the amount of

$2000.00

(3)

June 28, 2002 correspondence from Ashley Bravata to Daniel Sinclair

(4)

August 2, 2002 correspondence from Matthew M. Phillips to Daniel Sinclair regarding

satisfaction of Lease Finance Group Account # 0000297317

(5)

August 2, 2002 correspondence from Matthew M. Phillips to Daniel Sinclair regarding

satisfaction of Lease Finance Group Account # 0000359802

(6)

August 30, 2004 correspondence from Danny Sinclair to Equifax Mortgage Services



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(7)

August 30, 2004 correspondence from Danny Sinclair to Trans Union Consumer

Relations

(8)

October 3, 2000 correspondence from Samuel C. Taggard to Bill Lawson and Ashley

Grace

(9)

October 26, 2004 correspondence from Matthew M. Phillips to Daniel Sinclair, Jr.

regarding Lease Finance Group, Account # 088-0099372-000

(10) October 25, 2004 correspondence from Matthew M. Phillips to Daniel Sinclair, Jr.

regarding Lease Finance Group, Account # 088-0098437-000

(11) October 25, 2004 correspondence from Matthew M. Phillips to Daniel Sinclair, Jr.

regarding Lease Finance Group, Account # 088-0114496-000

(12) February 22, 2007 correspondence from Nicole Tooks to Daniel Sinclair

(13) February 16, 2007 correspondence from Kelly Gaines to Nicole Tooks

(14)

June 28, 2002 correspondence from Ashley Bravata to Louisiana Grill c/o Daniel Sinclair

(15)

June 27, 2002 correspondence from Ashley Bravata to Louisiana Grill c/o Daniel Sinclair

(16) Correspondence from Daniel Sinclair to TransUnion, Equifax and Experian

(17) Any and all loan documents for plaintiff and/or businesses with which he is associated

(18) Any and all insurance policies

(19) Any and all invoices

(20) Any and all cancelled checks

(21) 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

(22) Any and all photographs, videotapes, diagrams and/or drawings

(23) Any and all statements



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(24) Any and all pleadings, including attached exhibits

(25) Any and all discovery requests and responses (including subpoenas duces tecum and

responses) associated with this case

(26) Any and all affidavits

(27) Any and all documents produced by any party in initial disclosures

(28) Any and all exhibits listed or used by any other party in this case

(29) Any and all insurance policies

(30) All expert reports in this case

(31) Depositions taken in this case, including exhibits

Plaintiff reserves the right to supplement and/or amend this exhibit list as additional

documents and things may be disclosed through further investigation and during the discovery

process.

RESPECTFULLY SUBMITTED on this the 13th day of February, 2009.

DANIEL SINCLAIR, JR.

/s Hiawatha Northington II

HIAWATHA NORTHINGTON II, MSB #10831

























By:








OF COUNSEL:

SMITH & FAWER, LLC
774 Avery Boulevard North, Suite C
Ridgeland, MS 39157
Phone: 601.899.8726
Facsimile: 601.899.8727
[email protected]

201 St. Charles Ave., Suite 3702
New Orleans, LA 70130
Phone: 504.525.2200
Facsimile: 504.525.2205



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[email protected]
[email protected]


















































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CERTIFICATE OF SERVICE

I hereby certify that a copy of the above and foregoing has been forwarded to all known


counsel of record via the electronic filing system, this 13th

day of February, 2009.
































/s Hiawatha Northington II

Hiawatha Northington II















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