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 IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

 EASTERN DIVISION 

BARBARA JEFFERS and 

 JOAN CRAIG, ) 

) 

Plaintiffs, ) 

) CIVIL ACTION NO.: 

vs. CV-3:06-cv-00685-WKW 

) 

RUSSELL COUNTY BOARD OF ) 

 EDUCATION, et. al ) 

) 

Defendants. ) 

DEFENDANT RUSSELL COUNTY BOARD OF EDUCATION’S WITNESSES, 

DEPOSITION DESIGNATIONS, EXHIBITS AND TANGIBLE EVIDENCE

 COMES NOW THE DEFENDANT, Russell County Board of Education 

(hereinafter referred to as Board), submits herewith its Witnesses, Deposition 

Designations, Exhibits and tangible evidence. 

1. WITNESSES 

 A. The Board expects to call the following witnesses. 

 1. Dewilda “Dillie” Elliott 

 Member, Russell County Board of Education 

 

 . 2. Dr. Rebecca S. Lee 

 4219 Old Seale Highway 

 Seale, Alabama 36875 

 334-298-4330 

 Former Superintendent, Russell County Board of Education 

 3. Brenda Coley 

 Principal of Oliver Elementary 

 

 4. Charles Nacrelli 

 1402 Douglas Street 

 Opelika, AL 36801 

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 5. Jeri Nacrelli 

 1402 Douglas Street 

 Opelika, AL 36801 

 6. John Rudd 

 Transportation, Supervisor, Russell County Board of Education 

 

 7. Barbara Gunter 

 Central Office of Russell County Board of Education 

 Former assistant to Dr. Lee 

 8. Mrs. Lillian Baker 

 Assistant Superintendent for Personnel 

 9. Rose Fowles 

 Secretary at Ladonia Elementary 

 B. The Board may call the following witnesses if the need arises. 

 

 10. Robert Jason Hopper 

 Principal of Ladonia Elementary 

 

 11. Nuria Chaparro 

 Counselor, Russell County Board of Education 

 

 12. Jamie Evans 

 Smiths Station Primary School 

 150 Lee Road 295 

 Smiths, AL 36877 

 

 13. Alison Gentry 

 Teacher at Oliver Elementary 

 

 14. Kelly Howard 

 Westview Elementary School 

 1012 23rd Ave. 

 Phenix City, AL 36867 

 

 15. Beth Gaskins 

 Teacher at Ladonia Elementary 

 

 16. Jacqueline Grant 

 Alternative Learning Center 

 

 

 17. Keith Mitchell 

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 Member, Russell County Board of Education 

 18. Ken Coley 

 47 North Herring Road 

 Opelika, AL 36804 

 Husband of Brenda Coley 

 334-448-8799 

 

19. All of the names designated as witnesses by the Plaintiffs and 

the Defendant Nacrelli. 

 

 All of the above designated as Witnesses for the Board and for whom no specific 

addresses and/or phone numbers are given can be reached through the undersigned 

Counsel for the Board. 

2. DEPOSITION DESIGNATIONS 

 The Board does not know of any specific deposition designations at this time. 

Should any of the individuals who have been deposed either by Plaintiffs or Defendants 

not be available for the trial of this case, the Board may need to use all or portions of the 

depositions of those unavailable witnesses at the trial. In addition, the Board may use all 

or portions of the depositions taken by Plaintiffs and Defendants for impeachment 

purposes. 

 3. EXHIBITS AND TANGIBLE EVIDENCE 

 The Board may use any or all of the documentation received by Board from 

Plaintiffs in answers to discovery and any or all of the documentation produced by 

Defendants to Plaintiffs in answers to discovery. All documents attached as Exhibits to 

Depositions. All documents attached as Exhibits to Pleadings in this case. This will 

include, but not be limited to: Plaintiffs’ personnel files kept in the Central Office , 

Ladonia Elementary School and the Transportation Department; work schedules of the 

Plaintiffs; any written reports, grievances or statements of Plaintiffs complaining about 

their working conditions; portions of the personnel files of any employees of Defendant 

which have been produced; the policies, procedures and rules of Defendant including, but 

not limited to, any which pertain to counselors and school bus drivers; and Plaintiffs’ 

EEOC files. 

 Counsel for Plaintiffs and Defendant Nacrelli have all of the documentation 

referenced above. 

 All of the Exhibits and tangible evidence designated by the Plaintiffs and the 

Defendant Nacrelli. 

 The undersigned Counsel for the Board realizes that the designated Exhibits have 

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not been numbered and some of the Exhibits designated may not be used at trial. 

However, Counsel is waiting for the Court’s Order on its Motion for Summary Judgment 

as well as the results of Mediation which has been schedule for Friday, February 15, 

2008. Following those events Counsel for the Board will have the Exhibits marked for 

identification prior to trial and will include them as Ordered by this Court on February 6, 

2008 in Document 56. 

 This the 11th day of February, 2008 

 

 Smith & Smith, P.C. 

 /s/ Sydney S. Smith 

Attorneys for Defendant 

Russell County Board of Education 

1503 Broad Street 

Phenix City, AL 36867 

334-298-2679 

ASB-4248-T82S 

 

CERTIFICATE OF SERVICE

I hereby certify that I have filed today, February 11, 2008, by CM/ECF, the above and 

foregoing with copies being served upon: 

 W. Don Eddins, Esq. 

doneddins@charter.net

and 

Matthew C. Williams, Esq. 

matt@esw-law.com 

 /s/ Sydney S. Smith 

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