>> TABLE OF CONTENTS
CONTENTS
Directions for Determining Dates, Ages, Locations, and Applicable Law
Procedural and Factual History
Introduction
Issues Raised
The Parties and the Witnesses
Plaintiff
Plaintiff Witnesses
Defendant
Defendant Witnesses
The Competing Products and Services
Witnesses Available for Trial
Party and Witness Depositions and/or Statements
Admissibility of Evidence
Damage Witnesses
Exhibits and Documents
The Facts
Detailed Timeline of Significant Dates
Letter from General Counsel for NANO to General Counsel for St. Helens
Letter from General Counsel for St. Helens to General Counsel for NANO
NANO Facts
NANO Trade Secret Facts
Confidentiality Agreement between Erin Soderberg / NANO
Memo from Erin Soderberg to Kerry Collier
Memo from Kerry Collier to Erin Soderberg
Memo from Erin Soderberg to Kerry Collier
Resignation Memo from Erin Soderberg to Marty Greenfeld
Memo from Marty Greenfeld to Erin Soderberg
Metropolitan News [NANO has Billion Dollar Success]
Memo from Kerry Collier to Design Team for Anytime, Anywhere, People Locator
Memo from Kerry Collier to NANO Ex. Committee, Development Team, Advertising Dept
Metropolitan News [NANO launches Anytime, Anywhere, People Locator]
Metropolitan News [NANO New Headquarters]
NANO Damages Facts
Memo from NANO CFO, Chris Cook to Vivian Varnek and Ted Wade
Attachment A: Projected Sales Chart
Attachment B: Letter from Major Gil Frank to NANO
Attachment C: Letter from NYC Chief of Police Kathryn Landis to NANO
Attachment D: Letter from SF Chief of Police & Fire Dept., Robert Rheinman to NANO
Attachment E: Letter from Chris Cook to Major Gil Frank
Attachment F: Letter from Chris Cook to NYC Chief of Police, Kathryn Landis
Attachment G: Letter from Chris Cook to SF Chief of Police & Fire, Robert Rheinman
Attachment H: Letter from Margaret Hanson, Darngood Electronics to Chris Cook
Attachment I: Letter from Juliette Nelson-Picket, Picket Up Delivery Services to Chris Cook
Memo from NANO CFO, Chris Cook to Vivian Varnek and Ted Wade
With attached Letters of Rescission:
Attachment A: Letter from Major Gil Frank to Chris Cook
Attachment B: Letter from NYC Chief of Police, Kathryn Landis to Chris Cook
Attachment C: Letter from SF Chief of Police & Fire, Robert Rheinman to Chris Cook
St. Helens Facts
St Helens Trade Secret Facts
Letter from B. J. Rivera to Erin Soderberg
Letter from Erin Soderberg to B. J. Rivera
Memo from B.J. Rivera to Erin Soderberg with attached:
Employee Confidentiality Agreement between St. Helens and Erin Soderberg
Memo from Erin Soderberg to B.J. Rivera
Metropolitan News [St. Helens launches Family Finder]
St. Helens Damages Facts
Memo from Jan Willoughby to Fran Degrew
Attachment A: Sales Summary
Attachment B: Five Year Sales Summary--Units Sold
Attachment C: Five Year Sales Summary--Service Plans
Attachment D: Letter from Jan Willoughby to Major Gil Frank--US Army
Attachment E: Letter from Jan Willoughby to Kathryn Landis--NY City Police Dept
Attachment F: Letter from Jan Willoughby to Robert Rheinman--SF Police & Fire Dept
Attachment G: Letter from Major Gil Frank to Jan Willoughby
Attachment H: Letter from Kathryn Landis to Jan Willoughby
Attachment I: Letter from Robert Rheinman to Jan Willoughby
Pleadings
Complaint
Answer
Statements/Depositions
St. Helens Worldwide Technology?Erin Soderberg
B.J. Rivera
Jesse Stone
Jan Willoughby
NANO Search, Inc.?Kerry Collier
Marty Greenfeld
Pat Danville
Chris Cook
Appendices
Appendix A: Directions Burden of Proof
Order of Presentation
Suggested Time Schedules
Court Trial
Jury Trial
Expert Witnesses
Negotiation and Mediation
Appendix B: Applicable Law
Appendix C: Jury Instructions
Preliminary Instructions
Jury Deliberation
Appendix D: Special Verdict Form
EXHIBITS LIST [Exhibits located on CD]
Exhibit 1 LOGO--Anytime, Anywhere, People Locator
Witnesses: Collier, Rivera, Soderberg
Exhibit 2 LOGO--Family Finder
Witnesses: Collier, Rivera, Soderberg
Exhibit 3 NANO Confidentiality Agreement with Erin Soderberg
Witnesses: Greenfeld, Soderberg
Exhibit 4 Memo from Erin Soderberg to Kerry Collier [People Finder/Locator]
Witnesses: Collier, Soderberg
Exhibit 5 Memo from Kerry Collier to Erin Soderberg [People Finder/Locator]
Witnesses: Collier, Soderberg
Exhibit 6 Memo from Erin Soderberg to Kerry Collier
Witnesses: Collier, Soderberg
Exhibit 7 Resignation Memo from Erin Soderberg to Marty Greenfeld
Witnesses: Greenfeld, Soderberg
Exhibit 8 Memo from Marty Greenfeld to Erin Soderberg
Witnesses: Greenfeld, Soderberg
Exhibit 9 Memo from Kerry Collier to Design Team for Anytime, Anywhere, People Locator
Witness: Collier
Exhibit 10 Memo from Kerry Collier to NANO Executive Committee, Development Team, Advertising Department, Vivian Varnak, Ted Wade and Chris Cook
Witness: Collier, Cook
Exhibit 11 Metropolitan News Advertisement--Anytime, Anywhere, People Locator
Witnesses: Collier, Rivera, Soderberg
Exhibit 12 Memo from Cook to Vivian Varnek and Ted Wade with Attachments A--I
Witness: Cook
Exhibit 13 Memo From Chris Cook to Vivian Varnek and Ted Wade With Attachments A--C--Letters of Cancellation
Witness: Cook
Exhibit 14 Letter from B.J. Rivera to Erin Soderberg
Witnesses: Rivera, Soderberg
Exhibit 15 Letter from Erin Soderberg to B.J. Rivera
Witnesses: Rivera, Soderberg
Exhibit 16 Memo from B.J. Rivera to Erin Soderberg, St. Helens's Employee Confidentiality Agreement
Witnesses: Rivera, Soderberg
Exhibit 17 Memo from Erin Soderberg to B.J. Rivera
Witnesses: Rivera, Soderberg
Exhibit 18 Metropolitan News Advertisement--Family Finder
Witnesses: Collier, Rivera, Soderberg
Exhibit 19 Memo from Jan Willoughby to Fran Degrew With Attachments A--I--Charts and Letters
Witness: Willoughby
Exhibit 20 Highlighted Code Similarities of Anytime, Anywhere, People Locator and Family Finder
Exhibit 21 Highlighted Code Similarities of Anytime, Anywhere, People Locator and Family Finder
Supplemental Learning and Teaching Materials [Materials located on CD]
Section 1. General
Section 2. Negotiation
Section 3. Mediation
Section 4. Discovery
Section 5. Motions/Oral Argument
Section 6.Trial (Court/Jury)--Arbitration
Learning Objectives
Trial (Court/Jury)--Arbitration
Depositions
Negotiation
Mediation
Motions/Oral Argument
Expert Witnesses