IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

SEMIR D. SIRAZI, GREENSTONE 

CAPITAL, L.L.C. and MARDINI, INC.,

Plaintiffs,

vs.

GENERAL MEDITERRANEAN HOLDING, 

SA, ORIFARM, SA, and NADHMI AUCHI,

Defendants.

)

)

)

) Case No.: 1:12-cv-00653

)

) Hon. William T. Hart

)

)

)

)

)

DEFENDANTS’ PROPOSED TRIAL

EXHIBITS BEING OFFERED IN THEIR ORIGINAL FORM

NOW COME the defendants, General Mediterranean Holding, SA, Orifarm, SA, and

Nadhmi Auchi, by and through their attorneys, Law Offices of Joseph D. Ryan, P.C., and submit 

to the court the defendants’ proposed trial exhibits that the defendants will be offering at trial in 

their original form. With respect to this submission, the defendants state as follows:

1. On December 16, 2014, the parties submitted their Proposed Final Pretrial Order. 

(Docket No. 304).

2. In addition to the parties’ proposed joint trial exhibits, the Proposed Final Pretrial 

Order set forth the defendants’ proposed trial exhibits. (Docket No. 304-4, Schedule C-3: 

Defendants’ Offered Exhibits Not Objected To By Plaintiffs; Docket No. 304-5, Schedule C-4: 

Exhibits Offered By Defendants And Objected To By Plaintiffs).

Case: 1:12-cv-00653 Document #: 424 Filed: 05/12/15 Page 1 of 4 PageID #:18735
2

3. From amongst the defendants’ proposed trial exhibits set forth in the Proposed 

Final Pretrial Order, the defendants will be offering the following exhibits at trial in their original 

form; the exhibits are attached hereto under their respective designations:

a. DX 135; DX 148; DX 150; DX 154; DX 179; DX 185; DX 186; DX 187; 

DX 190; DX 282; DX 283; DX 287; DX 304; DX 308; DX 309; DX 312; 

DX 313; DX 314; DX 315; DX 334; DX 372; DX 374; DX 375; DX 376; 

DX 378; DX 388; DX 391; DX 392; DX 397; DX 403; DX 405; DX 407; 

DX 409; DX 410; DX 411; DX 412; DX 415; DX 425; DX 432; DX 434; 

DX 437; DX 440; DX 444; DX 445; DX 460; DX 465; DX 470.

4. From amongst the defendants’ proposed trial exhibits set forth in the Proposed 

Final Pretrial Order, the defendants withdraw the following exhibits and will not be offering 

them at trial:

a. DX 58; DX 125; DX 131; DX 136; DX 137; DX 139; DX 149; DX 151; DX 189; 

DX 225; DX 302; DX 307; DX 310; DX 382; DX 393; DX 394; DX 399; 

DX 400; DX 401; DX 402; DX 404; DX 406; DX 408; DX 413; DX 416; 

DX 418; DX 420; DX 421; DX 422; DX 424; DX 426; DX 428; DX 430; 

DX 435; DX 436; DX 439; DX 442; DX 443; DX 446; DX 448; DX 453; 

DX 456; DX 457; DX 459; DX 461; DX 462.

5. Contemporaneously with this submission, the defendants are separately filing two

related documents: Defendants’ Proposed Trial Exhibits Being Offered in Abstracted or 

Redacted Form; and Defendants’ Proposed Trial Exhibits that are Subject to Rulings of the 

Court.

Case: 1:12-cv-00653 Document #: 424 Filed: 05/12/15 Page 2 of 4 PageID #:18736
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WHEREFORE, the defendants, General Mediterranean Holding, SA, Orifarm, SA, and 

Nadhmi Auchi, respectfully request that the court issue an order deeming the attached exhibits to 

be admissible at trial, and/or that the court enter any order that it deems just and equitable.

Respectfully submitted,

General Mediterranean Holding, SA, Orifarm, SA,

and Nadhmi Auchi

/s/ Joseph D. Ryan

An attorney for the defendants 

Law Offices of Joseph D. Ryan, P.C.

1896 Sheridan Road

Highland Park, IL 60035

(847) 432-5971

ARDC # 6192344

Case: 1:12-cv-00653 Document #: 424 Filed: 05/12/15 Page 3 of 4 PageID #:18737
IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

SEMIR D. SIRAZI, GREENSTONE 

CAPITAL, L.L.C. and MARDINI, INC.,

Plaintiffs,

vs.

GENERAL MEDITERRANEAN HOLDING, 

SA, ORIFARM, SA, and NADHMI AUCHI,

Defendants.

)

)

)

) Case No.: 1:12-cv-00653

)

) Hon. William T. Hart

)

)

)

)

)

NOTICE OF FILING

To: Seth R. Yohalem

Scandaglia & Ryan

55 East Monroe, Suite 3440

Chicago, IL 60603

Please take notice that on May 12, 2015, we filed with the Clerk of the Court the attached 

Defendants’ Proposed Trial Exhibits Being Offered in their Original Form.

_____/s/ Joseph D. Ryan________________

Joseph D. Ryan

Law Offices of Joseph D. Ryan, P.C.

1896 Sheridan Road

Highland Park, IL 60035

(847) 432-5971

ARDC No. 6192344

CERTIFICATE OF SERVICE

I, Joseph D. Ryan, an attorney, state that service of this notice and accompanying 

document(s) was accomplished upon the individual(s) listed above pursuant to Electronic Case 

Filing as to Filing Users and in compliance with LR 5.5 as to any party who is not a Filing User 

or represented by a Filing User on May 12, 2015.

/s/ Joseph D. Ryan

 Joseph D. Ryan

Case: 1:12-cv-00653 Document #: 424 Filed: 05/12/15 Page 4 of 4 PageID #:18738