Why was an Agilent employee named by Varian Medical Systems, Inc. (VAR) as a witness who has sufficient knowledge to enable them to testify about Varian's damages?
"PLAINTIFF VARIAN MEDICAL SYSTEMS, INC.'S SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT MARY DAY'S FIRST SET OF "SPECIAL" INTERROGATORIES
Pursuant to Rules 26(e)(2) and 33 of the Federal Rules of Civil Procedure, as well as Magistrate Trumbull's Order Re Defendant Day's Motion for Order Compelling Responses to Discovery...
INTERROGATORY NO. 19:
If you contend that your reputation was damaged by any action undertaken by Defendant, DAY, IDENTIFY all persons who have sufficient knowledge of your reputation both before and after the actions to enable them to testify as to the amount of such damage.
RESPONSE TO INTERROGATORY NO. 19:
Varian Medical objects to this interrogatory ...
Varian Medical believes that the following persons have knowledge regarding the amount of damage to Varian Medical's reputation resulting from actions that Varian Medical believes were undertaken by Day and that form a basis for this lawsuit: Richard Levy, Richard Aurelio, George Zdasiuk, Sue Felch, Julie Fouquet.
...
DATED: Jan 31, 2000
Matthew H. Poppe
Attorneys for Plaintiffs
VARIAN MEDICAL SYSTEMS, INC. VARIAN
SEMICONDUCTOR EQUIPMENT ASSOCIATES,
INC., SUSAN B. FELCH, and GEORGE ZDASIUK"
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