UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JAMES TRACY, Plaintiff, Case No. 9:16-cv-80655-RLR v. FLORIDA ATLANTIC UNIVERSITY BOARD OF TRUSTEES, a/k/a FLORIDA ATLANTIC UNIVERSITY, et al. Defendants. 1 PLAINTIFF S FACT WITNESS LIST COMES NOW Plaintiff JAMES TRACY, by and through his undersigned attorneys, and in accordance with the Joint Scheduling Plan [DE 116] and Order Setting Pre-Trial Deadlines [DE 118], discloses the following fact witnesses for use at trial in this action. 1. All parties to this action. 2. Douglas C. Broadfield, Former Professor at Defendant FAU 3. Timothy Lenz, Professor at Defendant FAU 4. Chris Robé, Professor at Defendant FAU 5. Marshall DeRosa, Professor at Defendant FAU 6. Mike Budd, Emeritus Professor at Defendant FAU 7. Robert Rabil, Associate Professor at Defendant FAU 8. Ron Nyhan, Associate Professor at Defendant FAU 9. Fred Hoffman, Professor at Defendant FAU 10. Kenneth Holloway, Professor at Defendant FAU 11. Bill Bosshardt, Associate Professor at Defendant FAU 12. Susan Reilly, Professor at Defendant FAU 13. Jeffrey Morton, Professor at Defendant FAU
14. Thomas Wilson, Professor at Defendant FAU 15. Kevin M. Wagner, Professor at Defendant FAU 16. Stephen Kajiura, Associate Professor at Defendant FAU 17. Aaron Kula, Director of Music Performance & Education at Defendant FAU 18. James Cunningham, Instructor at Defendant FAU 19. Meredith Mountford, Associate Professor at Defendant FAU 20. Mary Jane Saunders, Professor at Defendant FAU 21. David C. Williams, Professor at Defendant FAU 22. Mohammad Ilyas, Professor and Dean at Defendant FAU 23. Shane Eason, Assistant Professor at Defendant FAU 24. Lynn Appleton, Professor at Defendant FAU 25. Brenda J. Claiborne, Professor at Defendant FAU 26. Patricia Kollander, Professor at Defendant FAU 27. Noemi Marin, Professor at Defendant FAU 28. Mark Scroggins, Former Professor at Defendant FAU 29. Jennifer Low, Former Professor at Defendant FAU 30. William Trapani, Associate Professor at Defendant FAU 31. Douglas T. McGetchin, Associate Professor at Defendant FAU 32. Ilene Prusher, Instructor at Defendant FAU 33. Christopher Beetle, Associate Professor at Defendant FAU 34. Gary Perry, Provost of Defendant FAU 35. Stacy Volnick, Vice President for Administrative Affairs and Chief Administrative Officer at Defendant FAU 2
36. Joshua Glanzer, Assistant Vice President for Media Relations and Public Affairs at Defendant FAU 37. Lisa Metcalf, Director of Media Relations and Chief Press Officer at Defendant FAU 38. Peter Hull, Vice President for Public Affairs at Defendant FAU 39. Linda Johnson, Associate Dean at Defendant FAU 40. Laura Winn, Instructor at Defendant FAU 41. Susan Prescott, Office Administrator and University Agency Clerk at Defendant FAU 42. Elisa Gaucher, Assistant Vice President for Research Integrity at Defendant FAU 43. David Kian, Vice President and General Counsel at Defendant FAU 44. Lawrence Glick, former General Counsel at Defendant FAU 45. Jack Ludin, General Counsel at Defendant FAU 46. Andrew LaPlant, Director, Board Operations & Chief Aide at Defendant FAU 47. Anthony Barbar, Chair of Board of Trustees of Defendant FAU 48. Jeffrey Feingold, Trustee of Defendant FAU 49. Marshall Ogletree (UFF, Executive Director of Defendant UFF 50. Jennifer Proffitt, President of Defendant UFF 51. All impeachment and/or rebuttal witnesses. 52. All witnesses listed by other parties. 53. Plaintiff reserves the right to and add any other fact witness(es as they are discovered and/or found to be deemed necessary in this matter. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 7th day of June, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 3
is being served this day on all counsel of record per the attached Service List via transmission of Notices of Electronic Filing generated by CM/ECF. /s/ Louis Leo IV Louis Leo IV, Esq. Florida Bar No. 83837 louis@floridacivilrights.org Florida Civil Rights Coalition, P.L.L.C. 4171 W. Hillsboro Blvd. Suite 9 Coconut Creek, FL 33073 Telephone: 954-478-4223 Fax: 954-239-7771 SERVICE LIST Louis Leo IV, Esq. (louis@floridacivilrights.org Joel Medgebow, Esq. (Joel@medgebowlaw.com Matthew Benzion, Esq. (mab@benzionlaw.com Florida Civil Rights Coalition, P.L.L.C., Medgebow Law, P.A. & Benzion Law, P.A. 4171 W. Hillsboro Blvd. Suite 9 Coconut Creek, Florida 33073 Counsel for Plaintiff Gerard J. Curely, Jr., Esq. (jcurley@gunster.com Keith E. Sonderling, Esq. (ksonderling@gunster.com Holly Griffin, Esq. (hgriffin@gunster.com Sara N. Huff, Esq. (shuff@gunster.com Gunster, Yoakley & Stewart, P.A. 777 South Flagler Dr. Suite 500 East West Palm Beach, FL 33401 Counsel for FAU Defendants 4
Robert F. McKee, Esq. (yborlaw@gmail.com Robert F. McKee, P.A. & Melissa C. Mihok, P.A. 1718 E. Seventh Ave. Ste. 301 Tampa, FL 33605 Counsel for Union Defendants 5