IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

BARBARA JEFFERS and )

JOAN CRAIG, )

Plaintiffs, )

v. ) CASE NO. 3:06-cv-685-WKW

RUSSELL COUNTY BOARD OF )

EDUCATION, et al., )

Defendants. )

PLAINTIFFS’ LIST OF WITNESSESS, EXHIBITS AND TANGIBLE EVIDENCE

AND DESIGNATION OF DEPOSTION TESTIMONY

COME NOW THE PLAINTIFFS and submit this Plaintiff’s List of Witnesses, Exhibits

and Tangible Evidence and Designation of Deposition Testimony:

Case 3:06-cv-00685-WKW-CSC Document 59 Filed 02/11/2008 Page 1 of 8
I. Witnesses

A. Plaintiffs expect to call

1. Plaintiff Barbara Jeffers

502 Highway 169

Seale, AL 36875

(334) 298-2867

2. Plaintiff Joan Craig

5 Willow Street

Phenix City, AL 36869

(334) 214-5181

3. Defendant Charles Nacrelli

1402 Douglas Street

Opelika, AL 36801

4. Dewilda “Dillie” Elliott

Member, Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

5. Garnett Lamar Booker

Lee County, Alabama

Nephew of Plaintiff Craig who witnessed battery.

6. Dianne McDaniel

Phenix City, AL

Former bus driver for Russell County Board of Education.

7. Shirley Baker

Phenix City, AL

Bus driver for Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

8. Lillian Baker

Assistant Superintendent/Personnel Director

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

9. Alison Gentry

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Teacher

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

10. Jamie Evans

Teacher

Smiths Station Elementary, Lee County Board of Education

150 Lee Road 295

Smiths, AL 36877

(334) 448-4422

11. Kelley Brantley Howard

Teacher

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

12. Rose Fowles

Secretary, Ladonia Elementary School

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

13. Brenda Coley

Principal, Oliver Elementary School

Seale, AL 36875

(334) 855-3225

14. Beth Gaskin

Teacher

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

15. Jacqueline Grant

Administrator

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

16. Dr. Rebecca Lee

4219 Old Seale Highway

Case 3:06-cv-00685-WKW-CSC Document 59 Filed 02/11/2008 Page 3 of 8
Seale, AL 36875

Former superintendent, Russell County Board of Education

(334) 298-4330

17. Nuria Chaparro

Counselor

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

18. Cheryl Garry Turk

Loachapoka, AL

Friend Ms. Craig confided in.

19. Paul Craig

5 Willow Street

Phenix City, AL 36869

(334) 214-5181

20. Harry Newman

5 Willow Street

Phenix City, AL 36869

Disabled brother of Ms. Craig

(334) 214-5181

21. Bill Faulk

502 Highway 169

Seale, AL 36875

(334) 298-2867

22. Dr. James Buford

(Expert witness)

337 E. Magnolia Avenue

Auburn, AL 36830

(334) 821-0125

B. Plaintiff may call

1. Jason Hopper

Principal

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

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2. Jeri Nacrelli

1402 Douglas Street

Opelika, AL 36801

3. Keith Mitchell

Member

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

4. Carolyn Bass

Columbus, GA

Retired teacher, Russell County Board of Education

5. Gwen Lewis

Teacher

Ladonia Elementary School

P.O. Box 400

Phenix City, AL 36868-0400

(334) 297-7313

6. Ken Coley

47 No. Herring Road

Opelika, AL 36804

7. Mr. John Rudd

Supervisor

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

8. Yvonne Amerson

Teacher

Russell County Board of Education

506 14th Street, Phenix City, AL 36867

(334) 298-8791

9. Dr. Janet Womack

Former principal, Russell County Board of Education

Auburn, AL 36830

10. Any witnesses from defendants’ lists and any witnesses needed for

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rebuttal or impeachment.

Defendants have deposed several of the witnesses. Others will testify about

plaintiffs’ being subjected to illegal touchings and comments and other

abuse, as well as plaintiffs’ reporting of same and how the abuse

affected plaintiffs. Plaintiffs’ counsel still is attempting to secure

addresses and phone numbers of some witnesses, but the information

will be produced soon.

II. Deposition designations

Plaintiffs expect to call as witnesses those persons who have been

deposed. However, in the event that any of the following witnesses is

unavailable, plaintiffs reserve the right to use deposition testimony of

Rebecca Lee, Dewilda Elliott, Lillian Baker and Brenda Coley. Plaintiffs

reserve the right to use deposition testimony for impeachment.

III. Exhibits, documents and tangible evidence

Plaintiffs expect to use the following exhibits which are hereby

designated as follows:

1. Exhibit A. Collectively, all documents relating to Mr. Nacrelli’s

losing his job as principal at Ladonia Elementary.

2. Exhibit B. Various sexual harassment policies of Russell County

Board of Education, including “official” policy (GAJDBH) and

handbook policy and bus driver manual policy.

3. Exhibit C. Personnel file, including the evaluations of Defendant

Nacrelli.

4. Exhibit D. Schedule of Plaintiff Jeffers from the 2005-6 Ladonia

Elementary School Handbook.

5. Exhibit E. Collection of photos taken at July 2005 school party

recognizing promotion of principal Coley. (Note: Defendants have

been shown the photographs and counsel for Defendant Nacrelli

apparently has copied them.)

6. Exhibit F. Personnel file of Plaintiff Jeffers.

7. Exhibit G. Personnel file of Plaintiff Craig.

Case 3:06-cv-00685-WKW-CSC Document 59 Filed 02/11/2008 Page 6 of 8
8. Exhibit H. Medical records of Plaintiff Jeffers.

9. Exhibit I. Medical records of Plaintiff Craig.

10. Exhibit J. Collectively, U.S. Equal Employment Opportunity

Commission files.

11. Exhibit K. Bus driver’s manual provided Ms. Craig for 2005-06

year.

12. Any exhibits not designated here but that were made exhibits to

depositions.

Defendants have most if not all the exhibits. Any defendants do not have

shall be promptly provided. Plaintiffs reserve the right to use any

exhibits designated by defendants. Plaintiffs reserve the right to use

exhibits, documents and tangible objects needed for rebuttal and

impeachment.

Final numbering and labeling of documents and exhibits will be completed

according to the Court’s February 6, 2008 Order (Doc. 56).

Respectfully,

/s/W. Don Eddins (ASB-1424-S65W)

Attorney for Plaintiffs

337 E. Magnolia Avenue

Auburn, AL 36830

(334) 821-9981

Facsimile (334) 826-7700

doneddins@charter.net

CERTIFICATE OF SERVICE

I, W. Don Eddins, counsel for Plaintiffs, hereby certify that on the 11th day of

February, 2008, I have electronically filed the foregoing with the Clerk of Court using the

CM/ECF system which will send notification of such filing to the following:

Sydney S. Smith, Esq. Matthew C. Williams, Esq.

Smith and Smith Estes, Sanders & Williams, LLC

Attorney for Russell Co. Bd. of Education Attorney from Mr. Nacrelli

Case 3:06-cv-00685-WKW-CSC Document 59 Filed 02/11/2008 Page 7 of 8
1503 Broad Street 3800 Colonnade Parkway, Ste. 330

Phenix City, AL 36830 Birmingham, AL 35243

ssmith4843@aol.com matt@asw-law.com

/s/W. Don Eddins (ASB-1424-S65W)

Attorney for Plaintiffs

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