ATTACHMENT A

WITNESS IDENTIFICATION FOR DEPOSITIONS

AND DOCUMENT PRODUCTION

A. Witness Identification for Depositions

1. Identify (the term "identify" shall mean the name, current title, job responsibilities, and work address) the persons most knowledgeable about the programming of Legacy's Siemens-Stromberg switch and the NAMS software. (Deposition of Curtis Brown, May 29, 2007: page 4: line 12 through page 5, line 6.)

2. Identify Legacy's IT Director who Curtis Brown met with to prepare for his deposition. (Deposition of Curtis Brown, May 29, 2007: page 4: line 12 through page 5, line 6.)

3. Identify Legacy's current IT Director.

4. Identify Legacy's IS Director who Curtis Brown met with to prepare for his deposition. (Deposition of Curtis Brown, May 29, 2007: page 4: line 12 through page 5, line 6.)

5. Identify Legacy's current IS Director.

6. Identify Legacy's Operations Manager who Curtis Brown met with to prepare for his deposition. (Deposition of Curtis Brown, May 29, 2007: page 4: line 12 through page 5, line 6.)

7. Identify Legacy's current Operations Manager.

8. Identify the person most knowledgeable about Legacy's VoIP hardware and software. (Deposition of Curtis Brown, May 29, 2007: page 8: lines 1-28; page 9: lines 22-28; page 10: Lines 1-18.)

B. Documents

1. Produce audited financial reports detailing the California element of Legacy's revenues for the years 2005, 2006, 2007, 2008, and 2009.

2. Produce all documents substantiating the fact that Legacy is providing telecommunication service in California.