Second Amended Notice of Intent to Call Witnesses and Introduce ...

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2. Harper, CindyPayne Financial Group Inc.2 2323 2 nd Ave. N.P.O. Box 306383 Billings, MT 59107-06384 Ms. Harper is an insurance producer at Payne Financial Group. She initially tookthe Defendant's claim that vandalism caused damage to his home. She was present5 when the Defendant called the insurance company repeated his claim. Ms. Harper isanticipated to testify regarding the Defendant's representations to the insurance6 company and to her.7 3. Norman, JenniferPayne Financial Group Inc.8 2323 2 nd Ave. N.P.O. Box 306389 Billings, MT 59107-063810 Ms. Norman is an insurance producer at Payne Financial Group and was theDefendant's insurance producer. Ms. Norman received and reviewed photographs11 that the Defendant submitted on behalf of his claim. Ms. Norman is anticipated totestify regarding what the Defendant told her, her handling of his claim, and to12 testify regarding the photographs submitted to her by the Defendant.13 4. Johnson, RyanTravelers Insurance Company14 RNCHO Cord Clm A260P.O. Box 1543915 Sacramento, CA 95851043916 Mr. Johnson was a claims representative for the insurance company. He surveyedthe damage to the Defendant's home on or about February 15,2011, with the17 Defendant. Mr. Johnson handled the Defendant's insurance claim. Mr. Johnson isanticipated to testify regarding what he observed at the house and what the18 Defendant told him in support of his insurance claim.19 5. Rex, Jim20Ron Maki InvestigationsP.O. Box 5019321Billings, MT 5910522 Mr. Rex is an investigator who works for insurance companies. Mr. Rexinterviewed the Defendant who again claimed that vandals caused the damage to his23 house and stole items. Specifically, the Defendant informed Mr. Rex that vandalsplugged the sinks with rags and turned the water on. Mr. Rex is anticipated to testify24regarding what the Defendant told him in support of the insurance claim.256. Any witness identified or called by the Defendant or the State through Discovery.SECOND AMENDED NOTICE OF INTENT TO CALL WITNESSES AND INTRODUCE EVIDENCE 2
1237. Any witness called by the Defendant8. Any rebuttal witness as necessary.4 Expert Witnesses:5 9. Robert Tehle.Master Plumber6 Alpine Plumbing, Heating, & Cooling306 Moore Lane,7 Billings, MT 591018 Mr. Tehle will testify as an expert concerning the water damage to the houselocated at 2475 S 17 Rd, in Ballantine, Montana. Mr. Tehle will testify that9 plugged sinks and fixtures did not cause damage to the house. Mr. Tehle willtestify as to the cause of the damage in the house, specifically, broken pipes.10Exhibits:111. Photographs Defendant submitted to the insurance company:12a. Broken Dishwasher (15:24)b. Downstairs Ceiling 2 (15:23)13c. Downstairs Ceiling (15 :20)d. Graffiti in Bathroom (15:38)14e. Ruined Carpet (15 :26)f. Stollen (sic) Refrigerator&Trim (sic) missing (15:24)15g. Wall Graffiti 2 (15:37)h. Wall Graffiti 3 (15:38)161. Wall Graffiti (15:37)J. 056 (15:27)17k. 057 (15:27)1. 067 (15 :30)182. Photographs taken pursuant to a search warrant on March 9, 2011.19a. IMG 1970b. IMG-197120c. IMG-1973d. IMG-197621e. IMG-1977f. IMG-197922g. IMG-1984h. IMG-1986231. IMG-1988J. IMG-198924k. IMG-19961. IMG-199725m. IMG-2001n. IMG-2003SECOND AMENDED NOTICE OF INTENT TO CALL WITNESSES AND INTRODUCE EVIDENCE 3
Page 1: 1 Jameson C. Walker (# 12-17838)Spe
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Second Amended Notice of Intent to Call Witnesses and Introduce ...

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