SUPPLEMENTAL DISCLOSURES 

PURSUANT TO FRCP 26(a) - 1 - 

Woodbery Law Group, P.S. 

800 Bellevue Way, N.E., Ste 400 

Bellevue, WA 98004 

Telephone (425) 637-3012 

Facsimile (425) 637-3014 

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 THE HONORABLE JAMES P. DONOHUE 

 

UNITED STATES DISTRICT COURT 

 WESTERN DISTRICT OF WASHINGTON 

 AT SEATTLE 

CHIHULY, INC. a Washington 

corporation and PORTLAND PRESS, 

a Washington corporation, 

 

 Plaintiffs, 

 Vs. 

ROBERT KAINDL, an individual; 

BRYAN RUBINO, individually and 

on behalf of his marital community; 

ART GLASS PRODUCTION, a 

Washington company; LAKESHORE 

GALLERY, LTD, a Washington 

corporation; KENNETH BEHM 

GALLERIES, LTD, a Washington 

corporation; TRAMMELL-GAGNE, 

LLC, a Washington limited liability 

company; and UNIK!, LLC, a 

Washington limited liability company, 

 Defendants. 

 NO. CV05-1801 

KENNETH BEHM GALLERIES, 

LTD’S SECOND SUPPLEMENTAL 

DISCLOSURES PURSUANT TO 

FRCP 26(a) 

COMES NOW the Defendant Kenneth Behm Galleries, Ltd pursuant to FRCP 

26(a) and makes the following supplemental disclosures: 
 

SUPPLEMENTAL DISCLOSURES 

PURSUANT TO FRCP 26(a) - 2 - 

Woodbery Law Group, P.S. 

800 Bellevue Way, N.E., Ste 400 

Bellevue, WA 98004 

Telephone (425) 637-3012 

Facsimile (425) 637-3014 

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A. Additional Persons with discoverable information: 

 The following individuals may be contacted through Counsel of Record 

for Kenneth Behm Galleries Ltd. at 800 Bellevue Way, N.E., Ste 400, Bellevue, 

WA 98004. 425-637-3012 or at the contact information herein provided; 

1. Amanda Hepworth- Employee at Defendant’s South Center gallery has 

knowledge obtained from conversations at the gallery with Robert Kaindl of his 

background and experience and that the glass art of his offered for sale at Kenneth 

Behm Galleries was created by him. She has knowledge of the general similarity 

of the type of glass art sold to that sold under the name or created by Dale 

Chihuly. She has observed similar glass art to this for sale in other galleries in the 

northwest and not under the name of Dale Chihuly. She has knowledge of the 

instruction gallery personnel received on the identity of the artist Robert Kaindl as 

having created the art for sale at Kenneth Behm Galleries. 

2. Lacey Hepworth- Former employee of Kenneth Behm Galleries at the 

Bellevue Square store. She personally sold several pieces of Kaindl art, met 

Robert Kaindl once at the gallery. The glass art sold or offered for sale at the 

gallery where she worked was always represented as instructed as having been 

created by Robert Kaindl. 

3. Zack Rubin 

 530 Melrose Ave. E. # 607 

 Seattle, WA 98102, 206-329-1945 

 
 

SUPPLEMENTAL DISCLOSURES 

PURSUANT TO FRCP 26(a) - 3 - 

Woodbery Law Group, P.S. 

800 Bellevue Way, N.E., Ste 400 

Bellevue, WA 98004 

Telephone (425) 637-3012 

Facsimile (425) 637-3014 

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Mr. Rubin is a former employee of Kenneth Behm Galleries, Ltd and has 

knowledge of the glass art of Robert Kaindl offered for sale at the gallery while 

employed there. He sold at least one piece of Kaindl glass art while he was so 

employed. 

4. Jessica Hurd 

 3106-130th Place N.E. 

 Bellevue, WA 98005 

 206-709-4104 

 

 Ms. Hurd is a former employee of Kenneth Behm Galleries and who sold 

at least one piece of Robert Kaindl glass art. 

5. Juliet Schubert, 206-786-5921 (current address unknown) is a former 

employee of Kenneth Behm Galleries Ltd. and has knowledge of two sales of 

Robert Kaindl glass art to customers in which she was involved. She had 

some contact with Kaindl and has knowledge of Kaindl’s representations as to 

his method in creating his glass work on a team concept and that he signed 

each piece offered for sale in the gallery. 

 Dated this 10th day of February, 2006. 

WOODBERY LAW GROUP, P.S. 

/s/ John E. Woodbery

John E Woodbery, WSBA # 08209 

Attorney for Defendant Kenneth 

Behm Galleries, Ltd. 

800 Bellevue Way, N.E. Ste 400 

Bellevue, WA 98004 

Phone (425) 637-3012 

Fax (425) 637-3014 

woodberylaw@lightreality.com
 

SUPPLEMENTAL DISCLOSURES 

PURSUANT TO FRCP 26(a) - 4 - 

Woodbery Law Group, P.S. 

800 Bellevue Way, N.E., Ste 400 

Bellevue, WA 98004 

Telephone (425) 637-3012 

Facsimile (425) 637-3014 

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 CERTIFICATE OF SERVICE 

I hereby certify that on February 10, 2006, I electronically filed with the clerk 

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

supplemental disclosures to the following : 

 O. Yale Lewis, Jr. oyl@hllaw.com; jw@hllaw.com 

 Kari L. O’Neil klo@hllaw.com; zed@hllaw.com 

 Bradford J. Axel bradford.axel@stokeslaw.com; cathy.regan@stokeslaw.com 

 Kathleen T. Petrich kathleen.petrich@stokeslaw.com; 

 Melanie.french@stokeslaw.com 

 Tolan S. Furusho tsf@premier1.net; tlm@premier1.net 

 Mark V. Jordan mjordan@invictalaw.com; manderson@invictalaw.com 

 Shilpa Bhatia Bhatia@wscd.com; castro@wscd.com 

 Steven W. Edmiston sedmiston@invictalaw.com

 Scott C. Wakefield swake@twlaw.com 

 

/s/ John E. Woodbery 

John E. Woodbery