IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

ANGELA PRICE, 

 Plaintiff, 

v. 

ROANOKE CITY BOARD OF 

EDUCATION, 

 Defendant. 

)

)

)

)

)

)

)

)

)

CIVIL ACTION NUMBER: 

3:06-cv-742-MEF 

DEFENDANT’S WITNESS AND EXHIBIT LIST 

Comes now Defendant, by and through the undersigned counsel of record, 

and hereby submits its trial list of exhibits and potential witnesses, in accordance 

with the Court’s Scheduling Order: 

Witnesses

Defendant may call some or all of the following persons to testify as 

witnesses1

 at the trial of this case: 

1. Angela Price 

2. Chuck Marcum 

 

1 Note: All witnesses are employees of the Defendant Roanoke City Board of 

Education. 

Case 3:06-cv-00742-MEF-WC Document 36 Filed 10/31/2007 Page 1 of 5
2

 3. Greg Foster 

 4. Robbie Benefield 

 5. Rosemarie Marshall 

 6. Jerrell Cottle 

 7. Chris Martin 

 8. Kristine Clarke 

 9. Theresa Hunter 

 10. Delia Harmon 

 11. Marilyn Pollard 

 12. Sherry Yarbrough 

13. Witnesses Listed by Plaintiff: All witnesses listed by Plaintiff in 

Plaintiff’s Witness and Exhibit List, which are incorporated by reference as if fully 

set forth herein. 

14. Any rebuttal witnesses necessary. 

15. Any individuals listed in the Plaintiff’s or Defendant’s initial 

disclosures or responses to interrogatories. 

16. Any individual who has been deposed or subpoenaed for trial by any 

party in this case. 

17. Any individual listed or called by the Plaintiff. 

Case 3:06-cv-00742-MEF-WC Document 36 Filed 10/31/2007 Page 2 of 5
3

18. Any witnesses added by amendment hereto as allowed by the Court. 

Exhibits

The following is a description of documentary evidence which Defendant 

intends to utilize at the trial of this case: 

 1. Excerpts from deposition of Angela Price: 11-12; 14-17; 20-29; 30-

34; 36-39; 41-47; 49; 50-53; 59; 60-66; 71-73; 95-96; 98-99; 102-104; 106-115; 

119-124; 127; 129; 130-131. 

 2. Excerpts from deposition of Chuck Marcum: 12-15; 18; 66; 48; 56; 

58; 69; 70; 76; 84-85; 87; 92; 94; 98. 

 3. Excerpts from deposition of Greg Foster: 6-8; 10-11. 

 4. Excerpts from deposition of Robbie Benefield: 6-9. 

 5. Excerpts from deposition of Rosemarie Marshall: 7-9; 15; 18; 20. 

 6. Affidavit of Jerrell Cottle 

 7. EEOC Charge of Discrimination 

 8. Excerpts from deposition of Jerrell Cottle: 10-14; 25. 

 9. Roanoke City Board of Education’s Sexual Harassment Policies 

 10. Affidavit of Greg Foster 

 11. Affidavit of Rosemarie Marshall 

 12. Affidavit of Robbie Benefield 

 13. Affidavit of Chuck Marcum 

Case 3:06-cv-00742-MEF-WC Document 36 Filed 10/31/2007 Page 3 of 5
4

 14. Affidavit of Chris Martin 

 15. Excerpts from deposition of Kristine Clarke: 9-10; 13-14. 

 16. Excerpts from deposition of Theresa Hunter: 7; 10; 17; 24. 

 17. Excerpts from deposition of Delia Harmon: 7; 9. 

 18. Excerpts from deposition of Marilyn Pollard: 7; 10; 12. 

 19. Excerpts from deposition of Sherry Yarbrough: 8-10; 12-14. 

20. All documents listed by Plaintiff which are incorporated by reference 

as if fully set forth herein, subject to the right of Defendant to object to the 

admissibility of such documents. 

21. Any document produced by Plaintiff in discovery. 

22. Any document produced by Defendant in discovery. 

23. Any document listed by Plaintiff as an exhibit. 

24. Any document required to rebut evidence offered at trial. 

25. Any document, not otherwise specifically identified herein, that has 

been made an exhibit to any deposition taken in this litigation. 

26. Plaintiff’s and Defendant’s responses to interrogatories, request for 

production of documents, and requests for admission. 

 s/Donald B. Sweeney, Jr. 

DONALD B. SWEENEY, JR. 

(SWE002) 

Case 3:06-cv-00742-MEF-WC Document 36 Filed 10/31/2007 Page 4 of 5
5

OF COUNSEL

Bradley Arant Rose & White LLP

One Federal Place 

1819 Fifth Avenue North 

Birmingham, AL 35203-2119 

Telephone: (205) 521-8000 

Facsimile: (205) 521-8800 

CERTIFICATE OF SERVICE

I hereby certify that on October 31, 2007, I electronically filed the 

foregoing with the Clerk of the Court using the CM/ECF system which will send 

notification of such filing to the following: 

Adam M. Porter, Esq. 

2301 Morris Avenue, Suite 102 

Birmingham, AL 35203 

and I hereby certify that I have mailed by United States Postal Service the 

document to the following non-CM/ECF participants: 

NONE 

Respectfully submitted, 

s/ Donald B. Sweeney, Jr. 

Donald B. Sweeney, Jr. 

(ASB-3803-W77D) 

Case 3:06-cv-00742-MEF-WC Document 36 Filed 10/31/2007 Page 5 of 5