FIRST SUPPLEMENT TO ILLINOIS CENTRAL RAILROAD COMPANY'S MOTION TO TRANSFER UNDER 28 U.S.C. § 1404(a)
Defendant, Illinois Central Railroad Company, moves the Court for an Order transferring this case to the United States District Court for the Western District of Tennessee pursuant to 28 U.S.C. § 1404(a). In support thereof, Illinois Central states:
1. On June 11, 2009, Plaintiff served his Initial Disclosure. Exhibit A.
2. Plaintiff has listed fifteen fact witnesses. Exhibit A. Nine of these witnesses were named in Illinois Central's Motion to Transfer. The five new witnesses are located as follows:
1 Melody McKnight -- Nesbit, MS Exhibit A.
2 Butch St. John - Southaven, MS 38671 Officed at 297 Rivergate Drive, Memphis, TN 38109
3 Mike McCorry -- address unknown (Defendant cannot determine that a Mike McCorry ever worked for Illinois Central)
4 Derek Taylor - Memphis, TN 38017 Officed at 297 Rivergate Drive, Memphis, TN 38109 until June of 2009 Transferred to Vancouver, British Columbia the week of June 15, 2009
5 Mark Doyle - Eads, TN 38028 Officed at 297 Rivergate Drive, Memphis, TN 38109
6 Steve Balwin -- address unknown (Defendant cannot find that a Steve Balwin was ever employed by Illinois Central).
Exhibit B, Second Affidavit of Charles Baker, Jr.
3. Further investigation has revealed that the following previously named witnesses have new current home addresses:
7 Brent Coleman - Cordova, TN 38016 Officed at 297 Rivergate Drive, Memphis, TN 38109
8 Brett Jury - Southaven, MS 38672 Officed at 297 Rivergate Drive, Memphis, TN 38109
4. In total, The Illinois Central employees who are potential witnesses with relevant personal knowledge have been ...