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Judge Zatkoff had ordered us to exchange witness lists by February 1,
2002 – and so I was not surprised to receive Taubman's witness list on that very day.
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
THE TAUBMAN COMPANY LIMITED PARTNERSHIP,
Plaintiff,
v. WEBFEATS and HENRY MISHKOFF
Defendants.
Civil Action No. 01-72987
Honorable Lawrence P. Zatkoff
Magistrate Judge Komives
PLAINTIFF'S WITNESS LIST
Plaintiff, The Taubman Company Limited Partnership, by and through its attorneys,
submit the following witness list:
Ari Charlip
The Taubman Company Limited Partnership
200 E. Long Lake Road, Suite 300
P.O. Box 200
Bloomfield Hills, MI 48303-0200
Dennis Hecht
The Taubman Company Limited Partnership
200 E. Long Lake Road, Suite 300
P.O. Box 200
Bloomfield Hills, MI 48303-0200
Donna Lynn Hartley
Hartley of Dallas
16400 Ledgemont Ln, Apt. 306
Addison, TX 75001
Henry Mishkoff
WebFeats
2661 Midway Road, #224-225
Carrollton, TX 75006
August.net Services, LLC (representative)
1000 E. Beltline Rd.
Suite 100
Carrollton, TX 75006
All witnesses named by Defendants.
All witnesses identified upon discovery in this matter.
Plaintiff, The Taubman Company Limited Partnership, hereby reserves the right to
supplement and add to the foregoing witness list as necessary.
Respectfully submitted,
Julie A. Greenberg (P38299)
GIFFORD, KRASS, GROH, SPRINKLE,
ANDERSON & CITKOWSKI, P.C.
280 N. Old Woodward, Suite 400
Birmingham, MI 48009
(248)647-6000
Fax: (248)647-5210
Date: 2/1/02
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View the Original List (in a
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I guess I shouldn't be shocked by the paucity of Ms. Greenberg's
witness list – I've known all along that she doesn't have much of a case, so it shouldn't
surprise me that she can't find too many people to testify against me. In fact, after mulling it over
for more than two months, the only witnesses she could dredge up are:
Two of Taubman's lawyers. I can't imagine what they could say that's relevant to the
case. I've actually spoken with one of them, we engaged in an abortive attempt at a settlement
discussion shortly after Taubman initiated their lawsuit against me – but since settlement
discussions cannot be introduced into evidence, I'm in the dark as to what he might be able to
contribute to this case.
My girlfriend. I suspect that Ms. Greenberg wants to ask Donna how many customers she
gleaned from the link that led from my "Mall" site to her ShirtBiz site for a few months. Donna's
already told me that the answer is zero, but I guess that Ms. Greenberg would like to hear that from
Donna.
Me. (Personally, I think I'll testify in my favor.)
My ISP. Why? Beats me. I have a sneaky suspicion that Ms. Greenberg believes that
August.net hosts my websites or co-locates my webserver, but neither is the case, I only buy bandwidth
from them. And she hasn't even bothered to take the time to get anyone's name, her witness is hazily
identified as a "representative." Doesn't that kind of defeat the purpose of a exchanging witness
lists? If I want to depose her witnesses, whom would I depose at August.net?
My witnesses. (Since she's been unable to think of anyone to testify on behalf of her
client, I guess that she's hoping that I'll be able to help her out...)
Anybody else whose name pops up in discovery. So even though the Judge ordered us to
exchange witness lists two weeks before the end of discovery, Ms. Greenberg is using this
clever dodge to circumvent the judge's order and is reserving the right to name additional witnesses
even after the discovery deadline!
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