IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

BARBARA M. JEFFERS and )

JOAN K. CRAIG, )

)

Plaintiffs, )

)

v. ) Civil Action Number:

) CV 3:06CV685-CSC

RUSSELL COUNTY BOARD OF )

EDUCATION and CHARLES )

NACRELLI, )

)

Defendants. )

)

DEFENDANT CHARLES NACRELLI’S WITNESSES,

DEPOSITION DESIGNATIONS, EXHIBITS AND TANGIBLE EVIDENCE

COMES NOW the Defendant, Charles Nacrelli, (hereinafter referred to as “Nacrelli”),

submits herewith its Witnesses, Deposition Designations, Exhibits and tangible evidence. 

I. WITNESSES

A. Nacrelli expects to call the following witnesses:

1. Barbara Jeffers, 502 Highway 169, Phenix City, Alabama 36875.

2. Joan K. Craig, 5 Willow Street, Phenix City, Alabama 36869.

3. Jason Hopper; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

4. Jacquelyn Grant; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

5. Rose Fowles; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

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6. Ila Parrish; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

7. Sherry Huckaby; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

8. David Chappell; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

9. Diane Oaks; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

10. Calvin Ross; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

11. Regina Giles; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

12. Traci Poole; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

13. Kathi Hornsby; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

14. Lisa Trammell; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

15. Kimberly Smith; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

16. Nuria Chapparro; Ladonia Elementary School, #9 Woodland

Drive, Phenix City, AL 36867

17. Sidney Oaks; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

18. JT Oaks; Ladonia Elementary School, #9 Woodland Drive, Phenix

City, AL 36867

19. Frank Henry; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

20. Cindy Crenshaw; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

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21. Tara Williams; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

22. Gwen Lewis; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

23. Deanna Peck; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

24. Shannon Gunter; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

25. Rita Loe; Ladonia Elementary School, #9 Woodland Drive, Phenix

City, AL 36867

26. Patriia Moore; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

27. Katrina Bussey; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

28. Beverly White; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

29. Krista Downing; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

30. William Smith; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

31. Becky Oliver; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

32. Callie Caudle; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

33. Don Hendrix; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867 

34. Shirley Baker; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

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35. Sara Allen; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

36. Felicia McNair; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

37. Dianne McDaniel; Ladonia Elementary School, #9 Woodland

Drive, Phenix City, AL 36867 

38. Janice Sigler; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

39. Beth Gaskin; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

40. Cile Parrish; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

41. Pam Frazier; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

42. Sheila Matthews; Ladonia Elementary School, #9 Woodland

Drive, Phenix City, AL 36867

43. Annie Riggins; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

44. Carolyn Dawson; Ladonia Elementary School, #9 Woodland

Drive, Phenix City, AL 36867

45. Johnnie Tinsley; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

46. Dreema Snead; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867

47. Ann Whatley; Ladonia Elementary School, #9 Woodland Drive,

Phenix City, AL 36867 

48. Becky Watson; Dixie Elementary School, 4914 US Highway 80

West, Opelika, AL 36804

49. Cindy Hankerson; Dixie Elementary School, 4914 US Highway 80

West, Opelika, AL 36804

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50. Barbara Clark; Dixie Elementary School, 4914 US Highway 80

West, Opelika, AL 36804

51. Marcia Johnson; Central Office, 506 14 Street, Phenix City AL. th

36867

52. Andrea Kuykendall; Central Office, 506 14 Street, Phenix City

th

AL. 36867

53. Paula Thompson; Central Office, 506 14 Street, Phenix City AL. th

36867

54. Kathy Hall; Central Office, 506 14 Street, Phenix City AL. 36867 th

55. Dilly Elliott; Central Office, 506 14 Street, Phenix City AL. th

36867

56. Keith Mitchell; Central Office, 506 14 Street, Phenix City AL. th

36867

57. Brenda Coley; at:Oliver Elementary, 77 Longview Drive, Seale,

AL 26875

58. Curtis Jernigan; at:Oliver Elementary, 77 Longview Drive, Seale,

AL 26875

59. Jennifer Wheeler; at:Oliver Elementary, 77 Longview Drive, Seale,

AL 26875 

60. Gail Davis; at:Oliver Elementary, 77 Longview Drive, Seale, AL

26875

61. Allison Gentry; at:Oliver Elementary, 77 Longview Drive, Seale,

AL 26875

62. Sheila Norris; at:Oliver Elementary, 77 Longview Drive, Seale, AL

26875

63. Cynthia Manderson; at:Oliver Elementary, 77 Longview Drive,

Seale, AL 26875

64. Larry Screws; Russell Elementary, 733 Railroad Street, Hurtsboro,

AL 36860

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65. Dolores McTier; Russell County High School, 4699 Old Seale

Highway, Seale, AL 36875

66. Nikki Robertson; Russell County High School, 4699 Old Seale

Highway, Seale, AL 36875

67. Polly Endfinger; Russell County High School, 4699 Old Seale

Highway, Seale, AL 36875

68. Bonnie Curry; Mount Olive Elementary, 464 State Highway 165

Mitchell, AL 36875

69. Felecia Barnes; Mount Olive Elementary, 464 State Highway 165

Mitchell, AL 36875

70. Jill Dexter; Mount Olive Elementary, 464 State Highway 165

Mitchell, AL 36875

71. Robin McCoy; Mount Olive Elementary, 464 State Highway 165

Mitchell, AL 36875

72. Gloria Crow; Mount Olive Elementary, 464 State Highway 165

Mitchell, AL 36875

73. Larry Dean Jeffers, Sr.; Address Unknown

74. Larry Dean Jeffers, Jr.; Address Unknown

75. Jeffery Morris Jeffers; Address Unknown

76. Matthew Jeffers; Address Unknown

77. Kenneth Coley; Address Unknown

78. Sidney Smith; Address Unknown

79. Ben Baker, Sr.; Address Unknown

80. Bill Faulk; Address Unknown

81. Ron Sheppard; Address Unknown

82. Glenna Sheppard; Address Unknown

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83. Alison Waldrop; Address Unknown

84. Neal Gentry; Address Unknown

85. Yvonne Amerson; Address Unknown

86. Kelly Brantley Howard; Address Unknown

87. Amy Harrell; Address Unknown

88. Jay Harrell; Address Unknown

89. Ben Baker, Jr.; Address Unknown

90. Bertha Alexander; Address Unknown

91. Cheryl Bevere; Address Unknown

92. Donna Kinsey; Address Unknown

93. Jackie Pugh; Address Unknown

94. Dotsie Carter; Address Unknown

95. Fred Lewis; Address Unknown

96. Henry Allen; Address Unknown

97. Tim Huckaby; Address Unknown

98. Jackie Pugh; Address Unknown

99. Alex Pugh; Address Unknown

100. Lori Matthews; Address Unknown

101. Mandy Weed; Address Unknown

102. Roland Bell; Address Unknown

103. Phyllis Ellison; Address Unknown

104. Judy King; Address Unknown

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105. Ruth Lieberman; Address Unknown

106. Warner Britton; Address Unknown

107. Sonya Franklin; Address Unknown

108. Rudy Barraca; Address Unknown

109. Theresa Nickerson; Address Unknown

110. Vicky Land; Address Unknown

111. Yvonne Tarver; Address Unknown

112. Julie Peletier; Address Unknown

113. Laura Lewis; Address Unknown

114. James Lowe; Address Unknown

115. Jamie Evans; Address Unknown

116. Janet Womack; Address Unknown

117. Janet Wommack; Address Unknown

118. Jim Davidson; Address Unknown

119. Jenny Lane; Address Unknown

120. Jodi Hankins McDaniel; Address Unknown

121. Joni Ryan; Address Unknown

122. Julie Maholick; Address Unknown

123. Lee Henderson; Address Unknown

124. T. Larry Thacker; Address Unknown

125. Dr. Rebecca Lee; Address Unknown

126. Lillian Baker; Address Unknown

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127. Lloyd Freye; Address Unknown

128. Mrs. Roland Bell; Address Unknown

129. Sheila; Address Unknown

130. Bobby Vaught; Address Unknown

131. Mr. Loe (Rita Loe’s husband); Address Unknown

132. Mr. Evans (Jamie Evan’s husband); Address Unknown

133. Mr. Gunter (Shannon Gunter’s husband); Address Unknown

134. Any witness, including any expert witness, identified by any other

party.

135. Rebuttal and/or impeachment witnesses whose testimony cannot

reasonably be anticipated at this time.

136. Any witness identified by any party during the course of the

discovery process.

137. Any custodian of records to prove the verification of authenticity of

any exhibit.

138. Any and all individuals identified in answers to interrogatories or

identified in discovery by and from any party to this action. 

II. EXHIBITS 

A. Nacrelli expects to use the following Exhibits:

1. The medical records of Ms. Jeffers from treatment at St. Francis

Hospital in Columbus, Georgia.

2. The medical records of Ms. Craig from treatment at St. Francis

Hospital in Columbus, Georgia

3. Results of any investigation conducted by the Russell County

Board of Education relating to improper conduct of Mr. Nacrelli.

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4. Copies of any statements given to any representative of the Russell

County Board of Education relating to allegations against Mr.

Nacrelli

5. Documents relating to the investigation of the charge of

discrimination filed with the U. S. Equal Employment Opportunity

Commission.

6. Minutes of the Russell County Board of Education at which the

Board voted to terminate Mr. Nacrelli’s employment.

7. A copy of the agreement between Mr. Nacrelli resigned rather than

to go on arbitration hearing.

8. All documents produced by any party to this action, not otherwise

objected to. 

9. All pleadings and attachments thereto.

10. Depositions of any person taken in this matter, and any

enlargements and portions thereof. 

11. All exhibits to the depositions of any person taken in this matter.

12. Any documents referenced in any party’s discovery responses.

13. Any documents provided by any third party, whether voluntarily or

in responses or in response to a subpoena for documents filed by

any party in this matter, including documents which have not been

produced as of the day of filing this exhibit list but which are

expected to be produced before trial. 

14. Any enlargements or “blow-ups” of the exhibits listed above,

which will be exact duplications of all or portions of the exhibits

listed above.

15. Demonstrative aids and charts of pertinent evidence.

16. Any documents relied upon by any expert testimony.

17. Any and all documents listed by any party subsequent to the

submission of this Witness & Exhibit list.

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18. Any and all documents that might otherwise be discovered through

additional depositions and/or additional discovery in this case but

which are unknown to Defendant as of the filing of this exhibit list.

19. Any and all exhibits needed to support a claim or defense of

Defendants, or to rebut or impeach any evidence or testimony or

any other party, which cannot reasonably be anticipated at this

time. 

20. All documents, diagrams, photographs and things listed as an

exhibit by Plaintiff or by any other party to this case and not

otherwise objected to. 

III. DEPOSITION DESIGNATIONS

Defendant Nacrelli 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, Defendant Nacrelli may need to use all or portions of the

depositions of those unavailable witnesses at the trial. In addition, Defendant Nacrelli may use

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

Respectfully submitted

/s/Matthew C. Williams 

MATTHEW C. WILLIAMS

CERTIFICATE OF SERVICE

I hereby certify that on the 11 day of February 2008, I electronically filed the foregoing th

with the Clerk of Court using the CM/ECF system, which will send notification of such filing to

the following: 

W. Don Eddins, Esq. 

Attorney at Law

337 E Magnolia Avenue, Suite #3

Auburn, Alabama 36830-3133

doneddins@charter.net

Attorney for Plaintiffs,

Barbara M. Jeffers and Joan K. Craig

Sydney S, Smith, Esq.

Smith & Smith

1503 Broad Street

Phenix City, Alabama 36867

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ssmith4843@aol.com

Attorney for Defendant,

Russell County Board of Education

/s/ Matthew C. Williams 

OF COUNSEL

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