Trial - Proposed Witness List (H0620061.DOC;1)



UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF NEW YORK

| |Civil Action No: |

|ARRELLO BARNES, |04-CV-0391 |

|Plaintiff, |(LES/DEP) |

|v. | |

|THOMAS RICKS, et al., | |

|Defendants. | |

PLAINTIFF’S PROPOSED WITNESS LIST

The plaintiff, Arrello Barnes, through assigned trial counsel, hereby submits the following list of individuals who will or may be called as witnesses in the above-captioned case.

1. Arrello Barnes, will testify that on September 18, 2002 he was cut by a piece of glass in his tuna fish. Mr. Barnes will testify that he complained of food tampering, to no avail, and that on the day he was injured defendants said “we told you we would get you”.

2. Steven Schule is a defendant in this action. He was formerly a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief

3. William Brown is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.

4. Jeremy McGaw is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.

5. Michael Riley is a defendant in this action. He is a correction officer at Upstate Correctional Facility and will testify concerning his job responsibilities and activities on the date in question. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.

6. Lieutenant Zerniack is not a defendant in this action. He was a Corrections Sergeant at Upstate Correctional Facility and will testify concerning his job responsibilities and the procedures he used to investigate the allegations presented by plaintiff that glass was placed in his food. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.

7. Sgt. Phillip Perry is not a defendant in this action. He is a Corrections Sergeant at Upstate Correctional Facility and will testify concerning his job responsibilities and the procedures he used to investigate the allegations presented by plaintiff that glass was placed in his food. In the interest of efficiency, plaintiff will examine this witness when he is called during the defendants’ case in chief.

Dated: November 16, 2007

Syracuse, New York Respectfully submitted,

Hancock & Estabrook, LLP

By:___________________________

Thomas C. Cambier, Esq.

Bar Roll No: 513780

Trial Counsel for Pro Se Plaintiff

Office and P.O.Address

1500 Tower I – P.O. Box 4976

Syracuse, New York 13221-4976

Telephone: (315) 471-3151

Telecopier: (315) 471-3167

Arrello Barnes, Pro Se Plaintiff

00-A-05597

Southport Correctional Facility

P.O. Box 2000

Pine City, New York 14901-2000

TO: Eliot Spitzer,

Attorney General of the State of New York

Attorney for Defendants

Office and P.O. Address

The Capitol

Albany, New York 12224-0341

Telephone: (518) 473-6288

Telecopier: (518) 473-1572

DOL #: 04-007073-O

Roger W. Kinsey, Of Counsel

Assistant Attorney General

Bar Roll No: 508171

Lawrence K. Baerman, Clerk

United States District Court

Northern District of New York

Federal Building and Courthouse

100 South Clinton Street

P.O. Box 7367

Syracuse, New York 13261-7367

CERTIFICATE OF SERVICE

I, Thomas C. Cambier, trial attorney for the plaintiff in this action, do hereby certify that on this date I caused the foregoing Plaintiff’s Proposed Witness List to be electronically served upon the following:

Roger W. Kinsey, Esq.

Assistant Attorney General

Office of the Attorney General

The Capitol

Albany, New York 12224-0341

Lawrence K. Baerman, Clerk

United States District Court

Federal Building and Courthouse

100 South Clinton Street

Syracuse, New York 13261

____________________________________

Thomas C. Cambier

Bar Roll No. 513780

Dated: November 16, 2007

Syracuse, New York

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