Persons with Knowledge · Ted Broomfield Law Website

Persons with Knowledge

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Summary

A list of people who have knowledge is an important tools in litigation. There are several reasons why a document list is so important. At trial, all evidence, including documents, is generally “admitted through a witness.” This means that the court or the jury considers the document in conjunction with the questions and answers of a witness. In general, only witnesses who were identified to the other side can be called at trial. So, in the process of discovery, detailed information on people with knowledge must be disclosed. Because it is the client, not the attorney who has knowledge of and access to learn the names, titles, and contact information of the people who have knowledge, it is important for the client to collect business cards, write down names and gather the identity of the persons who have impacted the case.

Details

A list of people who have knowledge an organized list of names, job titles or job functions, and contact information. Each person identified in the list states the exact name of the person, if known. If that person’s name is not known, the list states a job title or what that person did with respect to the matters involved in the litigation. The list also must include the contact information of the person.

If the person is not identified, then that person most likely cannot be a witness at trial.

This is critical, because, even if the client and attorney does not want the person to be a witness, it can help the case for the opposition to think certain people will be a witness. Additionally, even if the client and attorney does not want the person to be a witness, it can cost time if the opposition attempts to prevent a person from being a witness

If you read the article on chronology, you may recall the following chronology

Example Chronology

Before November 2, 2025, nobody knew which team would win Major League Baseball’s World Series.

On March 27, 2025, the 2025-Major League Baseball season started and every team had the same win-loss record, 0-0.

Between March 28, 2025 and the end of the 2025-regular season on September 28, 2025, the Los Angeles Dodgers led the National League West division.

On November 2, 2025, the the Los Angeles Dodgers defeated the Toronto Blue Jays to win game 7 of the 2025-World Series, and become the 2025 Major League World Series Champions.

After November 2, 2025, the the Los Angeles Dodgers were the 2025 Major League World Series Champions.

Example of a Document list

Based on that chronology is an Example of a List of Person’s with knowledge

John Doe was listed as the author of the 2025 Major League Baseball Schedule for all Major League teams, dated February 2, 2025, published by ESPN webpage, 52 pages. This person has knowledge of the 2025-MLB schedule.

Andrew Friedman was the president of operations for the Los Angeles Dodgers for at least the years 2024 and 2025. The contact information for this person is 1 Dodgers Stadium, Los Angeles, CA, with the telephone number (203) 555-1212. The email for this person is president@ladodgers.com. This person has knowledge of the facts, claims and defenses.

Dave Roberts was the was the head coach for the Los Angeles Dodgers for at least the years 2024 and 2025. The contact information for this person is 1 Dodgers Stadium, Los Angeles, CA, with the telephone number (203) 555-1212. The email for this person is headcoach@ladodgers.com. This person has knowledge of the facts, claims and defenses.

It gets more complicated

Obviously, this is a simple example, and a simple document list. Your case will definitely be more complicated.

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