IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

BRIAN BONNER, )

)

Plaintiff, )

)

vs. ) CASE NO. 3:06-cv-00715-MHT 

)

INTERSTATE ARMS CORP., et al., )

)

Defendants. )

WITNESS AND EXHIBITS LIST

COMES NOW the Plaintiff, Brian Bonner, and pursuant to this Honorable Court’s Pretrial 

Order, submits his Witness and Exhibit List as follows:

WITNESS LIST

Plaintiff provides the following list of individuals he may utilize, either live or by 

deposition, at the trial of this matter:

1. Brian Bonner, Plaintiff

2. Owena Knowles

3013 Hopewell Road

Valley, AL 36854

334-756-5878

3. Jim Knowles

3013 Hopewell Road

Valley, AL 36854

706-518-7597

4. Bobbie Dennis

503 Wellington Street

Valley, Alabama 36854

Phone Number Unknown

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5. Ralph Stewart

Address Unknown

Phone Number Unknown

6. B. J. Sadler

Address Unknown

Phone Number Unknown

7. Ms. Hu Jie

Qiqihar Hawk Industries Employee

8. Corporate representative of Qiqihar Hawk Industries

9. Corporate representative of Norinco a/k/a China North 

Industries Corporation

10. Corporate representative of Interstate Arms 

Corporation

11. John T. Butters, P.E.

Engineering Consultants, Inc.

158 Cook Lane

Center Point, TX 78010

12. Joseph M. Miller

207 Avenue “A” Southeast

Lafayette, AL 36862

13. William E. Hardy, Jr., Ph.D., J.D.

558 Merimont Blvd.

Auburn, AL 36830

14. Raymond Thompson

1500 1st Avenue North, Suite B117

Birmingham, AL 35203

15. Dr. Burton Sundin, M.D.

Kirklin Clinic

2000 6th Ave S

Birmingham, AL 35233

800) 822-8816

16. Dr.James N. Long

Kirklin Clinic

1802 6th Avenue South

Birmingham, AL 35249

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(205) 934-9999

17. Dr. Martin, Lanier Memorial Hospital

18. Any and all rebuttal witnesses.

19. Any person who was a witness to the incident or any consequence of the 

incident made the basis of this lawsuit.

20. Any person who has been deposed or who has yet to be deposed.

21. Any person who has signed interrogatory answers on behalf of any 

defendant.

22. Any witness whose name is listed as a witness for any defendant. 

23. Any witness who may be necessary to authenticate any document or item 

introduced as an exhibit, who cannot be anticipated at this time.

24. Any and all individuals who may have performed an investigation 

regarding the subject accident.

25. Any and all witnesses necessary to explain and/or clarify the testimony of 

any other witness.

26. Plaintiff reserves the right to assert additional witnesses at a later date.

EXHIBIT LIST

Plaintiff provides the following list of exhibits he intends to use at the trial of this matter. 

Plaintiff will provide any such documents for copying and inspection at the request of the 

Defendants.

1. Ay and all correspondence between the parties.

2. Any and all medical and billing records obtained from the University of 

Alabama Health Services Foundation.

3. Any and all medical and billing records obtained from UAB Hospital.

4. Any and all medical and billing records obtained from George Lanier 

Hospital.

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5. Any and all medical and billing records obtained from the Orthopaedic 

Clinic. 

6. Any and all medical and billing records obtained from East Alabama Medical 

Center.

7. Any and all medical and billing records obtained from Human Performance 

and Rehabilitation Centers.

8. Any and all medical and billing records obtained from Dr. James N. Long at 

the Kirklin Clinic.

9. Joint Stipulations regarding medical records executed by counsel for all 

parties.

10. Any and all photographs taken by the plaintiff.

11. Any and all photographs taken by any defendant.

12. Any and all photographs taken by any expert witness.

13. Any and all documents relied upon by expert John T. Butters, P.E.

14. Any and all documents relied upon by expert Joseph M. Miller.

15. Any and all documents relied upon by expert William E. Hardy, Jr., Ph.D., 

J.D.

16. Any and all documents and materials received in response to a subpoena(s) 

issued in this matter.

17. Any and all exhibits necessary for rebuttal and/or impeachment.

18. All Interrogatories propounded by any party, as well as the answers submitted 

thereto.

19. All documents produced during discovery by any and all parties.

20. All exhibits listed by the defendants.

21. Any and all deposition transcripts of witnesses in this case and exhibits 

attached thereto.

22. The twelve gauge shotgun at issue in this case. 

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23. Plaintiff reserves the right to add additional exhibits at a later date.

Respectfully submitted,

s/ David J. Hodge

Bar Number: ASB -4617-I71H

Of Counsel for Plaintiff

Pittman, Dutton, Kirby & Hellums, P.C.

2001 Park Place North

1100 Park Place Tower

Birmingham, Alabama 35203

(205) 322-8880

(205) 328-2711 facsimile

Email: PDKH-efiling@pdkhlaw.com

Nick Wooten, Esq.

THE WOOTEN LAW FIRM

P.O. Drawer 290

Lafayette, Alabama 36862

CERTIFICATE OF SERVICE

I hereby certify that on 11th day of August, 2008, 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: 

Todd M. Higey, Esq.

RICHARDSON CLEMENT, P.C.

200 Cahaba Park Circle, Suite 125

Birmingham, AL 35242

Attorney for Interstate Arms and Qiqihar Hawk

James C. Barton, Jr., Esq.

Alan D. Mathis, Esq.

JOHNSTON, BARTON, PROCTOR & POWELL, LLP

2900 Regions/Harbert Plaza

1901 6th Avenue North

Birmingham, AL 35203

Attorneys for Norinco

/s/David J. Hodge _____

Of Counsel for Plaintiff

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