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Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305
0E263 - J9
IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS
CIVIL DIVISION
ED MAP, INC.
Plaintiff,
Case No. 2018 CV 2305
Judge Cain
DELTA CAREER EDUCATION
CORPORATION, et al.,
Defendants.
PLAINTIFF ED MAP, INC.’S INITIAL DISCLOSURE OF WITNESSES
Plaintiff Ed Map, Inc. (“Ed Map”), pursuant to Local Rule 43 and the Clerk’s Original
Case Schedule filed on March 15, 2018, by and through counsel, identifies the following
witnesses who may be called to testify at trial
LAY WITNESSES:
1 Greg Smith, 296 Harper Street, Nelsonville, Ohio 450764, Ed Map Chief
Financial Officer, may testify regarding the agreement between Ed Map and Delta and Ed Map’s
provision of services to the Ancora Defendants. This witness can be contacted through counsel
for Ed Map.
2. Bill Nance, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, former
employee of Delta Career Education Corporation (“Delta”) and current employee of STVT-AAI
Education, Inc. (“Ancora Education”) may testify, as on cross examination, regarding the
agreement between Ed Map and Delta and the assumption of that agreement by Ancora
Intermediate Holdings LLC (“Ancora Holdings”) and/or Ancora Education (collectively, the
“Ancora Defendants”).
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305
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3 Timothy Ryder, 8406 Stone Gate Drive, Apt. 7, Annandale, Virginia 22003,
phone number unknown, Delta’s former Chief Financial Officer, may testify about the
transaction between Delta and the Ancora Defendants and the agreement between Ed Map and
Delta.
4 Martina Hansen fka Martina Jorve, 8618 Conover Place, Alexandria, Virginia
22308, phone number unknown, a former executive of Delta, may testify about the asset
purchase agreement between Delta and the Ancora Defendants and the agreement between Ed
Map and Delta.
5 Michael Zawisky, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, an
executive of Ancora Education, may testify, as on cross examination, about the services provided
by Ed Map to Ancora Education and the transaction between Delta and the Ancora Defendants.
6 A representative of Ancora Intermediate Holdings LLC, 8701 Bedford Euless
Road, Suite 400, Hurst, Texas 76053, may testify, as on cross examination, about the relationship
between Ed Map, Delta, and the Ancora Defendants.
7 A representative of Ancora Education, 8701 Bedford Euless Road, Suite 400,
Hurst, Texas 76053, may testify, as on cross examination, about the relationship between Ed
Map, Delta, and the Ancora Defendants.
8 Ed Map reserves the right to call any and all witnesses disclosed by any other
party, any person deposed in this case by any party, and any document custodian identified by
any party to this case regarding all issues raised in the litigation
9 Ed Map reserves the right to supplement this list as appropriate, and Ed Map
reserves the right to call rebuttal and impeachment witnesses as appropriate.
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305
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EXPERT WITNESSES:
1 Ed Map reserves the right to elicit expert testimony from any expert witness
identified by any other party to this case.
2. Discovery is on-going, and Ed Map reserves the right to identify an expert witness
should discovery warrant the need for Ed Map to retain an expert witness.
3 Ed Map reserves the right to supplement this list as appropriate.
Respectfully submitted,
/s/ Allen T. Carter
Elizabeth L. Moyo (0081051)
Allen T. Carter (0085393)
41 South High Street, Suite 2800
Columbus, Ohio 43215
Tel: (614) 227-2000
Fax: (614) 227-2100
Email: emoyo@porterwright com
Email: acarier@porterwright.com
Attorneys for Plaintiff id Map, Inc.
CERTIFICATE OF SERVICE
The undersigned certifies that on August 2, 2018, the foregoing was served via the
court’s electronic filing system on the following
C. Craig Woods, Esq
Andrew H. King, Esq
Michael T. Mullaly, Esq
Squire Patton Boggs (US) LLP
2000 Huntington Center
41 South High Street
Columbus, Ohio 43125
Counsel for Defendants
STVT-AAI Education, Inc.
dba Ancora Education and
Ancora Intermediate Holdings LLC
/s/ Allen T. Carter
Allen T. Carter
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305 0E263 - J9 IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ED MAP, INC. Plaintiff, Case No. 2018 CV 2305 Judge Cain DELTA CAREER EDUCATION CORPORATION, et al., Defendants. PLAINTIFF ED MAP, INC.’S INITIAL DISCLOSURE OF WITNESSES Plaintiff Ed Map, Inc. (“Ed Map”), pursuant to Local Rule 43 and the Clerk’s Original Case Schedule filed on March 15, 2018, by and through counsel, identifies the following witnesses who may be called to testify at trial LAY WITNESSES: 1 Greg Smith, 296 Harper Street, Nelsonville, Ohio 450764, Ed Map Chief Financial Officer, may testify regarding the agreement between Ed Map and Delta and Ed Map’s provision of services to the Ancora Defendants. This witness can be contacted through counsel for Ed Map. 2. Bill Nance, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, former employee of Delta Career Education Corporation (“Delta”) and current employee of STVT-AAI Education, Inc. (“Ancora Education”) may testify, as on cross examination, regarding the agreement between Ed Map and Delta and the assumption of that agreement by Ancora Intermediate Holdings LLC (“Ancora Holdings”) and/or Ancora Education (collectively, the “Ancora Defendants”). Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305 0E263 - J9 3 Timothy Ryder, 8406 Stone Gate Drive, Apt. 7, Annandale, Virginia 22003, phone number unknown, Delta’s former Chief Financial Officer, may testify about the transaction between Delta and the Ancora Defendants and the agreement between Ed Map and Delta. 4 Martina Hansen fka Martina Jorve, 8618 Conover Place, Alexandria, Virginia 22308, phone number unknown, a former executive of Delta, may testify about the asset purchase agreement between Delta and the Ancora Defendants and the agreement between Ed Map and Delta. 5 Michael Zawisky, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, an executive of Ancora Education, may testify, as on cross examination, about the services provided by Ed Map to Ancora Education and the transaction between Delta and the Ancora Defendants. 6 A representative of Ancora Intermediate Holdings LLC, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, may testify, as on cross examination, about the relationship between Ed Map, Delta, and the Ancora Defendants. 7 A representative of Ancora Education, 8701 Bedford Euless Road, Suite 400, Hurst, Texas 76053, may testify, as on cross examination, about the relationship between Ed Map, Delta, and the Ancora Defendants. 8 Ed Map reserves the right to call any and all witnesses disclosed by any other party, any person deposed in this case by any party, and any document custodian identified by any party to this case regarding all issues raised in the litigation 9 Ed Map reserves the right to supplement this list as appropriate, and Ed Map reserves the right to call rebuttal and impeachment witnesses as appropriate. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Aug 02 3:27 PM-18CV002305 0E263 - J9 EXPERT WITNESSES: 1 Ed Map reserves the right to elicit expert testimony from any expert witness identified by any other party to this case. 2. Discovery is on-going, and Ed Map reserves the right to identify an expert witness should discovery warrant the need for Ed Map to retain an expert witness. 3 Ed Map reserves the right to supplement this list as appropriate. Respectfully submitted, /s/ Allen T. Carter Elizabeth L. Moyo (0081051) Allen T. Carter (0085393) 41 South High Street, Suite 2800 Columbus, Ohio 43215 Tel: (614) 227-2000 Fax: (614) 227-2100 Email: emoyo@porterwright com Email: acarier@porterwright.com Attorneys for Plaintiff id Map, Inc. CERTIFICATE OF SERVICE The undersigned certifies that on August 2, 2018, the foregoing was served via the court’s electronic filing system on the following C. Craig Woods, Esq Andrew H. King, Esq Michael T. Mullaly, Esq Squire Patton Boggs (US) LLP 2000 Huntington Center 41 South High Street Columbus, Ohio 43125 Counsel for Defendants STVT-AAI Education, Inc. dba Ancora Education and Ancora Intermediate Holdings LLC /s/ Allen T. Carter Allen T. Carter