UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
ARRELLO BARNES,Plaintiff,
v.
THOMAS RICKS, et al.,
Defendants. / Civil Action No:
04-CV-0391
(LES/DEP)
PLAINTIFF’S PROPOSED WITNESS LIST
The plaintiff, Arrello Barnes, through assigned trial counsel, hereby submits the following list of individuals who will or may be called as witnesses in the above-captioned case.
1. Arrello Barnes, will testify that on September 18, 2002 he was cut by a piece of glass in his tuna fish. Mr. Barnes will testify that he complained of food tampering, to no avail, and that on the day he was injured defendants said “we told you we would get you”.
2. Steven Schule is a defendant in this action. He was formerly a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief
3. William Brown is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.
4. Jeremy McGaw is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.
5. Michael Riley is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.
6. Lieutenant Zerniack is not a defendant in this action. He was a Corrections Sergeant at Upstate Correctional Facility and will testify concerning his job responsibilities and the procedures he used to investigate the allegations presented by plaintiff that glass was placed in his food. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.
7. Sgt. Phillip Perry is not a defendant in this action. He is a Corrections Sergeant at Upstate Correctional Facility and will testify concerning his job responsibilities and the procedures he used to investigate the allegations presented by plaintiff that glass was placed in his food. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.
Dated: November 16, 2007
Syracuse, New York Respectfully submitted,
Hancock & Estabrook, LLP
By:______
Thomas C. Cambier, Esq.
Bar Roll No: 513780
Trial Counsel for Pro Se Plaintiff
Office and P.O.Address
1500 Tower I – P.O. Box 4976
Syracuse, New York 13221-4976
Telephone: (315) 471-3151
Telecopier: (315) 471-3167
Arrello Barnes, Pro Se Plaintiff
00-A-05597
Southport Correctional Facility
P.O. Box 2000
Pine City, New York 14901-2000
TO: Eliot Spitzer,
Attorney General of the State of New York
Attorney for Defendants
Office and P.O. Address
The Capitol
Albany, New York 12224-0341
Telephone: (518) 473-6288
Telecopier: (518) 473-1572
DOL #: 04-007073-O
Roger W. Kinsey, Of Counsel
Assistant Attorney General
Bar Roll No: 508171
Lawrence K. Baerman, Clerk
United States District Court
Northern District of New York
Federal Building and Courthouse
100 South Clinton Street
P.O. Box 7367
Syracuse, New York 13261-7367
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CERTIFICATE OF SERVICE
I, Thomas C. Cambier, trial attorney for the plaintiff in this action, do hereby certify that on this date I caused the foregoing Plaintiff’s Proposed Witness List to be electronically served upon the following:
Roger W. Kinsey, Esq.
Assistant Attorney General
Office of the Attorney General
The Capitol
Albany, New York 12224-0341
Lawrence K. Baerman, Clerk
United States District Court
Federal Building and Courthouse
100 South Clinton Street
Syracuse, New York 13261
______
Thomas C. Cambier
Bar Roll No. 513780
Dated: November 16, 2007
Syracuse, New York
4
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