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Robert Groden v Frank Gorka and City of Dallas

Robert Groden v Frank Gorka and City of Dallas

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Published by Robert Wilonsky
Previewing the case over being able to sell JFK lit and merch at Dealey Plaza
Previewing the case over being able to sell JFK lit and merch at Dealey Plaza

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Published by: Robert Wilonsky on May 19, 2014
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06/15/2014

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PLAINTIFF’S
WITNESS LIST Page | 1
IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION ROBERT GRODEN, Plaintiff, v. CITY OF DALLAS, TEXAS and SERGEANT FRANK GORKA, Defendants. § § § § § § § § § § CIVIL ACTION NO. 3:10-cv-01280-F
PLAINTIFF’S
WITNESS LIST
COMES NOW, Robert Groden (“Plaintiff” or “Groden”)
, and
 pursuant the Court’s Octobe
r 30, 2013 Order Setting Trial, Local Rule 26.2, and Rule 26(a)(3) of the Federal Rules of Civil Procedure, files this
Plaintiff’s
Witness List, and for same would respectfully show unto the Court as follows:
I.
PLAINTIFF’S
WITNESSES
Plaintiff may call the following witnesses to testify at trial: 1.)
 
Peter A. Schulte, Esq. Schulte & Apgar, PLLC 4131 N. Central Expwy, Suite 680 Dallas, Texas 75204 (214) 521-2200
Plaintiff’s Expert Witness
 Mr. Schulte
is Plaintiff’s expert witness, and
is of the opinion that the arrest, property seizure, and prosecution of Plaintiff by Defendant in this case were not appropriate, not based on  probable cause, not supported by the law, and not justified and that Defendant Sergeant Frank Gorka should not be entitled to qualified immunity. Mr. Schulte is expected to testify on and  present evidence under Rules 702, 703, and 705 of the Federal Rules of Evidence on the subject of the propriety of the arrest and prosecution of Plaintiff, as well as the property seizure, by Defendant and whether Defendant Gorka should be entitled to qualified immunity.
Case 3:10-cv-01280-N Document 119 Filed 05/12/14 Page 1 of 8 PageID 1256
 
PLAINTIFF’S
WITNESS LIST Page | 2
Mr. Schulte is a licensed attorney in Texas, a former prosecutor, and former police officer. He continues to maintain both his Texas Commission on Law Enforcement Officer Standards and Education (TCLEOSE) Instructor License and his Peace Officer License. He teaches area police officers arrest, search, and seizure law at police academies in North Texas.
Mr. Schulte’s estimate length of direct examination is
thirty (30) minutes. 2.)
 
 Nicola Longford c/o Randy A. Nelson Thompson, Coe, Cousins, & Irons, L.L.P. 700 N. Pearl Street, Twenty-Fifth Floor Dallas, Texas75201 (214) 871-8228 Ms. Longford is an employee of The Sixth Floor Museum at Dealey Plaza, and was involved in development and execution of the plan to eliminate competitors of The Sixth Floor Museum at Dealey Plaza by wrongfully arresting Plaintiff Groden. Ms. Longford knew that the
legal basis for Plaintiff’s arrest was invalid, and she
 is expected to testify as to this.
Ms. Longford’s
estimate length of direct examination is thirty (30) minutes. 3.)
 
Bradley Hamilton c/o Randy A. Nelson Thompson, Coe, Cousins, & Irons, L.L.P. 700 N. Pearl Street, Twenty-Fifth Floor Dallas, Texas75201 (214) 871-8228 Mr. Hamilton is a former employee of The Sixth Floor Museum at Dealey Plaza, and was involved in development and execution of the plan to eliminate competitors of The Sixth Floor Museum at Dealey Plaza by wrongfully arresting Plaintiff Groden. Mr. Hamilton contacted the City of Dallas Police Department about Plaintiff prior to his wrongful arrest, and is expected to testify as to this.
Mr. Hamilton’s
estimate length of direct examination is thirty (30) minutes. 4.)
 
Vincent Golbeck c/o Patricia M. De Le Garza
Assistant City Attorney’s Office
 1500 Marilla Street, Room 7D North Dallas, Texas 75201 (214) 670-3519 Mr. Golbeck is a former police officer for the City of Dallas, and was involved in development and execution of the plan with The Sixth Floor Museum at Dealey Plaza to eliminate
Case 3:10-cv-01280-N Document 119 Filed 05/12/14 Page 2 of 8 PageID 1257
 
PLAINTIFF’S
WITNESS LIST Page | 3
competitors of The Sixth Floor Museum at Dealey Plaza. Mr. Golbeck contacted Defendant Gorka about Plaintiff prior to his wrongful arrest, and is expected to testify regarding this.
Mr. Golbeck’s
estimate length of direct examination is one (1) hour. 5.)
 
Carla Newson c/o Patricia M. De Le Garza
Assistant City Attorney’s Office
 1500 Marilla Street, Room 7D North Dallas, Texas 75201 (214) 670-3519 Ms. Newson is a former employee the City of Dallas, and signed the criminal Complaint dated July 13, 2010, wherein Plaintiff was wrongfully charged by Defendant Gorka. Ms. Newson is expected to testify as to whether the facts stated in the criminal Complaint she signed are true or false, and whether that Defendant Gorka actually provided her with valid grounds to charge Plaintiff.
Ms. Newson’s
estimate length of direct examination is thirty (30) minutes. 6.)
 
Raquel Hernandez c/o Patricia M. De Le Garza
Assistant City Attorney’s Office
 1500 Marilla Street, Room 7D North Dallas, Texas 75201 (214) 670-3519 Ms. Hernandez is a former employee the City of Dallas, and signed the criminal Complaint dated June 13, 2010, wherein Plaintiff was wrongfully charged by Defendant Gorka. Ms. Hernandez is expected to testify as to whether the facts stated in the criminal Complaint she signed are true or false, and whether Defendant Gorka actually provided her with valid grounds to charge Plaintiff.
Ms. Hernandez’s
estimate length of direct examination is thirty (30) minutes. 7.)
 
Steve Worden 1301 E. Spring Valley Road Richardson, Texas 75081 Mr. Worden is a former employee the City of Dallas and conspired with The Sixth Floor Museum at Dealey Plaza to eliminate the competitors of The Sixth Floor Museum at Dealey Plaza,  pursuant to which Plaintiff was wrongfully arrested by Defendant Frank Gorka. Mr. Worden knew that Chapter 32, Section 32-10 of the Dallas City Ordinance was not applicable, and is expected to testify as to this plan
Mr. Worden’s
estimate length of direct examination is thirty (30) minutes. 
Case 3:10-cv-01280-N Document 119 Filed 05/12/14 Page 3 of 8 PageID 1258

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