This is a compilation of admissible evidence (on the face) for Rossi v. Darden, insofar as it has been revealed through public filings. It includes responses to interrogatories, quoted in requests for judicial intervention or in other motions, deposition excerpts (or a few are complete), and attested exhibits (as with motions for summary judgment).
A separate section will cover documents provided (such as emails); strictly speaking, these are not admissible without some attestation of authenticity. However, where included in the later Motions, they have been included and are not separately listed.
The expert reports are included, though it is not clear that they include “penalty of perjury” attestations.
Except for the separate section, these are in order of date or DE number, which amounts to the same sort.
== 0070.1_IH_response_to_1st_Rossi_interrog
== 0070-4_vaughn_response_to_1st_rossi_interrog
== 0138.1_Mazzarino_Affidavit covering founding of IH and relationship with IH
== 0158.1_Dewey_Weaver_declaration (on behalf of DRV)
== 0167.8_Exhibit_7 Deposition of Dewey Weaver
== 0179.6_Exhibit_6 Deposition of Vaughn
== 0179.7_Exhibit_7 Deposition of Fogelman for IPH
== 0179.8_Exhibit_8 Deposition of Fogelman for Cherokee
== 0183.1_Exhibit_A Meyers Bigel representation agreement
== 0183.2_Exhibit_B IH-DRV agreement
== 0183.4_Exhibit_D Declaration of Dewey Weaver re NK Patent Law (same as 158-1)
== 0194.01_Exhibit 1 Expert report of Rick A. Smith, P.E.
== 0194.02_Exhibit_2 Deposition of T. Barker Dameron (IH engineer)
== 0194.03_Exhibit_3 Deposition of Leonardo Corp by Rossi + Darden-Penon emails
== 0194.05_Exhibit 5 Expert disclosure of Joseph A. Murray (not the disclosure, a description.)
== 0194.06_Exhibit_6 Video Deposition of Wong (Rossi expert)
== 0194.07_Exhibit_7 Video Deposition of Rossi
== 0194.08_Exhibit_8 Video Deposition of JM Products by Rossi
== 0194.09_Exhibit_9 Deposition of Fabio Penon
== 0194.10_Exhibit_10 Deposition of Fulvio Fabiani (apparently)
== 0194.15_Exhibit_15 Declaration of J.T. Vaughn
== 0197.01_Exhibit_1 Expert disclosure of Kaifui V. Wong
== 0197.02_Exhibit_2 Video deposition of Wong
At this point, documents are being asserted with Motions for Summary Judgment and responses. These documents should be attested as true. I have not checked this. Some of these documents are also from various motions and may not be attested.
== 0207.01_Exhibit_1 10.5 MB file License Agreement
== 0207.02_Exhibit 2 Deposition of Rossi
== 0207.03_ Exhibit_3 email Rossi to Darden and Vaughn, April 23, 2013.
== 0207.04_Exhibit_4 Rossi to Darden and Vaughn, April 24, 2013.
== 0207.05_Exhibit_5 1st Amendment to License Agreement
== 0207.06_Exhibit_6 Declaration of Thomas F. Darden
== 0207.07_Exhibit_7 Assignment of License Agreement to IPH
== 0207.08_Exhibit_8 Rossi certification re representations in Agreement
== 0207.09_Exhibit_9 7.3 MB file Deposition of Darden
== 0207.10_Exhibit_10 Deposition of Penon
== 0207.11_Exhibit_11 email Penon to Darden Validation Test 2013
== 0207.12_Exhibit_12 Deposition of Cassarino (Ampenergo)
== 0207.13_Exhibit_13 $3,219,950 paid, IH to Ampenergo, 2013.
== 0207.14_Exhibit_14 formal Admissions of Rossi
== 0207.15_Exhibit_15 2nd Amendment to License Agreement
== 0207.16_Exhibit_16 Contribution Agreement, IH & Ampenergo
== 0207.17_Exhibit_17 Deposition of Leonardo, rep by Rossi
== 0207.18_Exhibit_18 email Cassarino, Rossi, Darden, Boeing
== 0207.19_Exhibit_19 deposition of Industrial Heat, rep by Vaughn
== 0207.20_Exhibit_20 Six Cylinder Unit (photos)
== 0207.21_Exhibit_21 Rossi Deposition of Vaughn
== 0207.22_Exhibit_22 (Filed under seal) see 247-01 – Exhibit 22
== 0207.23_Exhibit_23 (blank) see 251-01 – Exhibit 23 Declaration of Vaughn
== 0207.24_Exhibit_24 Rossi responses to interrog.
== 0207.25_Exhibit_25 Rossi emails to supporters
== 0207.26_Exhibit_26 IH responses to interrog.
== 0207.27_Exhibit_27 Pace to Annesser 2/17/2016 re patent assignment
== 0207.28_Exhibit_28 Declaration of Pace re Exhibit 27
== 0207.29_Exhibit_29 IPH reponses to Rossi interrog.
== 0207.30_Exhibit_30 (filed under seal) see == 247-02 – Exhibit 30
== 0207.31_Exhibit_31 (filed under seal) see 247-03 – Exhibit 31
== 0207.32_Exhibit_32 (filed under seal) see 247-04 – Exhibit 32
== 0207.33_Exhibit_33 (filed under seal) see 247-05 – Exhibit 33
== 0207.34_Exhibit_34 emails Rossi (prev exhibit 16) re Doral proposal
== 0207.35_Exhibit_35 email Rossi/Darden, re Ampenergo, IH Memo to investors
== 0207.36_Exhibit_36 Deposition of JMP, represented by Rossi
== 0207.37_Exhibit_37 Deposition of Johnson
== 0207.38_Exhibit_38 JMC/JMP corporate papers
== 0207.39_Exhibit_39 Darden/Rossi negotiations re Test Sheet
== 0207.40_Exhibit_40 Darden/Rossi re JM not wanting to disclose identity
== 0207.41_Exhitbit_41 Rossi describes interactions with the customer “in London.”
== 0207.42_Exhibit_42 marked up Term Sheet
== 0207.43_Exhibit_43 Johnson provides OFAC declaration of ownership to IH
== 0207.44_Exhibit_44 Rossi March 2015 RFP for Johnson Matthey for 10 kg platinum sponge
== 0207.45_Exhibit_45 Term Sheet (prev exhibit 17)
== 0207.46_Exhibit_46 Rossi email to Johnson about rental of Doral and eviction
== 0207.47_Exhibit_47 various Rossi emails
== 0207.48_Exhibit_48 Deposition of Bass
== 0207.49_Exhibit_49 Rossi to Darden 2/19/2015
== 0207.50_Exhibit_50 Rossi – Johnson re power reports to IH & “Johnson Matthey”
== 0207.51_Exhibit_51 Bass business card
== 0207.52_Exhibit_52 deposition of James Stokes, Florida Department of Health
== 0207.53_Exhibit_53 Rossi 9/2014 to Johnson
== 0207.54_Exhibit_54 Rossi to Johnson re address of JMP
== 0207.55_Exhibit_55 Penon data
== 0207.56_Exhibit_56 deposition of Fabiani
== 0207.57_Exhibit_57 deposition of Murray (for full copy see 0215.03)
== 0207.58_Exhibit_58 Penon all reports as of February 23, 2016
== 0207.59_Exhibit_59 Florida Power & Light data
== 0207.60_Exhibit_60 deposition of T. Barker Dameron
== 0207.61_Exhibit_61 deposition of Barry West
== 0207.62_Exhibit_62 Rossi instructions to Bass, March 24. 2015, and February 15, 2016
== 0207.63_Exhibit_63 Rossi to Vaughn refusing entry to Murray 7/13/2015 (former Exhibit 19)
== 0207.64_Exhibit_64 12/9/2015, Vaughn to Rossi/Johnson requesting visit, Johnson response
== 0207.65_Exhibit_65 Queries for Penon by Murray, former Exhibit 5.
== 0207.66_Exhibit_66 payments from IH to USQL
== 0207.67_Exhibit_67 3.9 MB file IH/USQL Agreement
== 0207.68_Exhibit_68 4.2 MB file Vaughn/Fabiani mails re 2014 Agreement
== 0207.69_Exhibit_69 11.3 MB file IH/USQL Agreement 9/1/2015 to3/31/2016
== 0207.70_Exhibit_70 3.5 MB file Fabiani to Vaughn 4/2016, Murray to Fabiani 5/2016
== 0207.71_Exhibit_71 Murray to Fabiani 3/22/2016 and 4/1/2016
== 0207.72_Exhibit_72 Murray to Fabiani 4/26/2016 and 5/16/2016
== 0207.73_Exhibit_73 Mail from Fabiani to Murray 4/25/2016
== 0207.74_Exhibit_74 Fabiani to IH 4/6/2016
== 0207.75_Exhibit_75 corporate confirmation Leonardo New Hampshire active 3/21/2017
== 0214.01 Exhibit_1 Affidavit of Andrea Rossi
== 0214.02 Exhibit_2 Deposition of Fogelman for Cherokee
== 0214.03 Exhibit 2A Cherokee web page
== 0214.04 Exhibit 3 Deposition of Vaughn for Industrial Heat
== 0214.05 Exhibit 4 3.6 MB file License Agreement and 2013 wire transfer
== 0214.06 Exhibit 5 First Amendment to License Agreement
== 0214.07 Exhibit 6 Assignment to IPH
== 0214.08 Exhibit 7 2.1 MB file Second Amendment to License Agreement
== 0214.09 Exhibit 8 Amended Assignment and Assumption to IPH
== 0214.10 Exhibit 9 Deposition of Darden
== 0214.11 Exhibit 10 Rossi email re Validation Test
== 0214.12 Exhibit 11 Dewey Weaver critique of Validation Test protocol
== 0214.13 Exhibit 12 Penon report on 2013 Validation Test
== 0214.14 Exhibit 13 Deposition of Vaughn
== 0214.15 Exhibit 14 Deposition of Murray (see also full deposition at 215.03)
== 0214.16 Exhibit 15 Validation Agreement re 2013 transfer of payment and IP
== 0214.17 Exhibit 16 Validation verification notice
== 0214.18 Exhibit 17 IPH deposition by Fogelman
== 0214.19 Exhibit 18 IH response to Rossi Interrogatory 2
== 0214.20 Exhibit 19 email Weaver to Vaughn, and Vaughn to Darden re 2013 test
== 0214.21 Exhibit 20 deposition of T. Barker Dameron
== 0214.22 Exhibit 21 Vaughn to Darden 2013 re activities
== 0214.23 Exhibit 22 7.0 MB file IH business plan and 2014 memo
== 0214.24 Exhibit 23 Rossi to Darden about Validation test. (duplicates Ex. 11?)
== 0214.25 Exhibit 24 Vaughn, 2012-2014 timeline
== 0214.26 Exhibit 25 Rossi/Penon “test plan.” 2/10/2015
== 0214.27 Exhibit 26 Rossi to Darden 2/19/2015
== 0214.28 Exhibit 27 Deposition of Smith (see full copy at 215.04)
== 0214.29 Exhibit 28 12/2/2013 Vaughn to Weaver experimental report
== 0214.30 Exhibit 29 2/19/2015 Rossi to McLaughlin (APCO)
== 0214.31 Exhibit 30 2/2/2015 Joe Pike to Rossi
== 0214.32 Exhibit 31 2/21/2015 Pike to Rossi
== 0214.33 Exhibit 32 2.1 MB file draft Penon Report
== 0214.34 Exhibit 33 IH responses to Rossi interrogatories 1
== 0214.35 Exhibit 34 April 2015 Darden Memo to Lamacraft (Woodford)
== 0214.36 Exhibit 35 March 4, 2016 on IH press release
== 0214.37 Exhibit 36 Final Penon report
== 0214.38 Exhibit 37 Vaughn re Rossi/Cook paper
== 0214.39 Exhibit 38 Darden to Rossi re Rossi/Cook paper
== 0214.40 Exhibit 39 Darden to Rossi congratulating him on Rossi/Cook paper
== 0214.41 Exhibit 40 Rossi to Vaughn explaining that his attorney being CEO of JMP is a “guarantee.”
== 0214.42 Exhibit 41 Darden to Pike raising “picky issues,” 3/23/2015
== 0215.01_Exhibit_A Expert Disclosure of Joseph A. Murray
== 0215.02_Exhibit_B Expert Report of Rick A. Smith, P.E.
== 0215.03_Exhibit_C 5.6 MB file Full Deposition of Murray
== 0215.04_Exhibit_D 5.9 MB file Full Deposition of Smith
== 0226.3_Attachment_3 Deposition of Thomas Darden re lack of Ampenergo signature & GPT
== 0228.1_Exhibit_A Darden testimony
== 0228.2_Exhibit_B Declaration of Uzi Shaya re Levi Declaration
== 0233.1_Exhibit_A Expert disclosure of Murray (duplicates Rossi 0215.01_Exhibit_A)
== 0233.2_Exhibit_B Expert report of Smith (duplicates Rossi 0215.02_Exhibit_B)
== 0233.3_Exhibit_C Expert disclosure of Wong (duplicates IH 0197.01_Exhibit_1)
== 0233.4_Exhibit_D Deposition of Rick A. Smith (excerpt from Rossi 0215.04_Exhibit_D)
== 0233.5_Exhibit_E Deposition of Murray (excerpt from Rossi 0215.03_Exhibit_C)
== 0235.01_Exhibit_1 Smith expert report
== 0235.02_Exhibit_2 about Murray expert report
== 0235.03_Exhibit_3 IH request for access to Doral premises
== 0235.04_Exhibit_4 negotiations re access 3 MB file.
== 0235.05_Exhibit_5 Declaration of Smith re results of access to Doral
== 0235.06_Exhibit_6 Deposition of Rossi
== 0235.07_Exhibit_7 Deposition of Rossi
== 0235.08_Exhibit_8 Deposition of JMP represented by Rossi
== 0235.09_Exhibit_9 Murray — Supplemental documents
== 0235.10_Exhibit_10 Smith supplemental report 2 MB file.
== 0235.11_Exhibit_11 Composite: Murray/Darden/Fabiani/Vaughn/etc., July 2015 concerns 3 MB file.
== 0235.12_Exhibit_12 Disclosures of parties
== 0235.13_Exhibit_13 Deposition of Smith
== 0235.14_Exhibit_14 Deposition of Penon
== 0235.15_Exhibit_15 Deposition of T. Barker Dameron
== 236-01 – Exhibit 1 Deposition for Cherokee by Fogleman
== 236-02 – Exhibit 2 Declaration of Darden
== 236-03 – Exhibit 3 Deposition of Darden 7 MB file
== 236-04 – Exhibit 4 Deposition for Ampenergo by Cassarino
== 236-05 – Exhibit 5 Deposition for Industrial Heat by Vaughn
== 236-06 – Exhibit 6 Deposition of Vaughn
== 236-07 – Exhibit 7 Notes from telephone conversations, Cassarino (Ampenergo)
== 236-08 – Exhibit 8 Deposition for IPH by Fogleman 4.9 MB file
== 236-09 – Exhibit 9 emails Darden and Rossi June 2015
== 236-10 – Exhibit 10 Term Sheet (signed Rossi, Vaughn, Johnson)
== 236-11 – Exhibit 11 IPH resp and obj to 1st Rossi interrog
== 236-12 – Exhibit 12 Rossi JONP (blog) posts
== 236-13 – Exhibit 13 Deposition for Leonardo by Rossi
== 236-14 – Exhibit 14 Leonardo Fed Inc tax returns 2012, 2013 15.9 MB file
== 236-15 – Exhibit 15 Deposition of Rossi
== 236-16 – Exhibit 16 Email Vaughn, Rossi 2013
== 236-17 – Exhibit 17 Deposition of Penon
== 236-18 – Exhibit 18 Email Penon to IH, first eval, May 2013
== 236-19 – Exhibit 19 Email Rossi – IH, 2012
== 236-20 – Exhibit 20 Agreement – Ampenergo and IH 2013 modifying 2012 Agmt
== 236-21 – Exhibit 21 Email Rossi, Vaughn, Cassarino, Boeing, 2014
== 236-22 – Exhibit 22 6 Cylinder Unit photos
== 236-23 – Exhibit 23 Rossi response to 1st IH Request for Admissions
== 236-24 – Exhibit 24 IH responses and obj to 2nd Rossi interrog
== 236-25 – Exhibit 25 Feb. 2016 Letter Pace to Annesser re license assignment 3.8 MB file
== 236-26 – Exhibit 26 Declaration of Pace, IH counsel, re 236-25
== 236-27 – Exhibit 27 IH journal entries payments to Rossi
== 236-28 – Exhibit 28 Rossi – Darden 2014 emails
== 236-29 – Exhibit 29 email July 2014 Darden-Cassarino-Vaughn-Mazzarino-Rossi
== 236-30 – Exhibit 30 deposition of Johnson
== 236-31 – Exhibit 31 Rossi 2014 emails to Darden and Vaughn re customer identity
== 236-32 – Exhibit 32 2014 emails Johnson-Vaughn, including signed OFAC declaration
== 236-33 – Exhibit 33 JMP deposition by Rossi
== 236-34 – Exhibit 34 deposition of Bass
== 236-35 – Exhibit 35 Rossi instructions to Johnson secretary
== 236-36 – Exhibit 36 deposition of Stokes
== 236-37 – Exhibit 37 Leonardo sublease Doral to JMP
== 236-38 – Exhibit 38 2015 emails Rossi-IH-Mazzarino et al-Johnson-Cassarino et al-Bass
== 236-39 – Exhibit 39 February 2015 emails Rossi-IH-J&D Pike
== 236-40 – Exhibit 40 Johnson to IH invoice requests – email Rossi – Johnson (Sauer)
== 236-41 – Exhibit 41 Bass business card as Director of Engineering for JMP
== 236-42 – Exhibit 42 Rossi instructions to Johnson re JMP address and invoice request
== 236-43 – Exhibit 43 Plant data – Penon report – handwritten temperature record 3.3 MB file
== 236-44 – Exhibit 44 deposition of Fabiani
== 236-45 – Exhibit 45 deposition of Murray
== 236-46 – Exhibit 46 email Feb 2016 Penon to IH – Expert Disclosure of Murray 2.5 MB file
== 236-47 – Exhibit 47 Florida Power & Light subpoena and data 3.6 MB file
== 236-48 – Exhibit 48 deposition of Dameron
== 236-49 – Exhibit 49 deposition of West
== 236-50 – Exhibit 50 emails Feb-Mar 2015 Rossi-Bass
== 236-51 – Exhibit 51 emails July 2015 Rossi-Vaughn re Murray visit etc
== 236-52 – Exhibit 52 2015 emails IH-Rossi-Johnson re proposed December plant visit
== 236-53 – Exhibit 53 Murray queries for Penon, original exhibit 5
== 236-54 – Exhibit 54 report of IH payments to USQL (Fabiani)
== 236-55 – Exhibit 55 certificate of good standing, Leonardo New Hampshire
== 238-01 – Exhibit 43 Incorporation Leonardo Florida 2010 1.9 MB file
== 238-02 – Exhibit 44 2013 email Rossi-IH re Validation Test
== 238-03 – Exhibit 45 deposition of Rossi
== 238-04 – Exhibit 46 affidavit of Rossi supporting opposition to IH MSJ
== 238-05 – Exhibit 47 deposition for IPH by Fogleman
== 238-06 – Exhibit 48 deposition of Vaughn
== 238-07 – Exhibit 49 2013 email Vaughn-Rossi re closing on $10 million payment
== 238-08 – Exhibit 50 deposition of Darden
== 238-09 – Exhibit 51 2014 radiation safety email to Darden
== 238-10 – Exhibit 52 deposition for Industrial Heat by Vaughn
== 238-11 – Exhibit 53 2014 emails Rossi-Darden re customer for plant power
== 238-12 – Exhibit 54 2013 emails Rossi-IH re Validation Test
== 238-13 – Exhibit 55 deposition for Ampenergo by Cassarino
== 238-14 – Exhibit 56 emails 2014 Rossi-IH re customer plan
== 238-15 – Exhibit 57 deposition of Johnson
== 238-16 – Exhibit 58 June 2014 email Rossi to IH and Joe Pike
== 238-17 – Exhibit 59 deposition for Leonardo by Rossi
== 238-18 – Exhibit 60 Term Sheet revision display
== 238-19 – Exhibit 61 Darden July 2014 email re Term Sheet
== 238-20 – Exhibit 62 Johnson OFAC declaration
== 238-21 – Exhibit 63 deposition of Barry West
== 238-22 – Exhibit 64 deposition for JMP by Rossi
== 238-23 – Exhibit 65 deposition of Penon
== 238-24 – Exhibit 66 expert disclosure of Wong
== 238-25 – Exhibit 67 test (by IH? 2014?) showing COP 4 2.1 MB file
== 238-26 – Exhibit 68 deposition of Mazzarino
== 238-27 – Exhibit 69 2013 Vaughn to Darden re 6 cylinder unit
== 238-28 – Exhibit 70 2014 IH internal mails re testing
== 238-29 – Exhibit 71 supplement to IH responses and obj to 1st Rossi interrog
== 242.1 Exhibit A deposition of Darden
== 242.2 Exhibit B deposition for IH by Vaughn
== 242.3 Exhibit C deposition of Mazzarino
== 242.4 Exhibit D deposition of Barry West
== 242.5 Exhibit E deposition of Bass 3.1 MB
== 242.6 Exhibit F deposition of Vaughn
== 242.7 Exhibit G deposition of Murray
== 242.8 Exhibit H deposition of Penon
== 242.9 Exhibit I deposition of Dameron
== 242.10 Exhibit J deposition of Johnson
== 242.11 Exhibit K airline record for Johnson from Rossi 7/28/2014
== 242.12 Exhibit L emails Sauer-Bass 9/2014
== 242.13 Exhibit M affidavit of Rossi re Fabiani and Bass
== 242.14 Exhibit N IH resp to 1st Rossi interrogatories
== 243-01 – Exhibit A deposition of Darden excerpts
== 243-02 – Exhibit B deposition for IH by Vaughn excerpts
== 243-03 – Exhibit C deposition of Mazzarino excerpts
== 243-04 – Exhibit D deposition of West excerpts
== 243-05 – Exhibit E deposition of Bass excerpts 3.1 MB
== 243-06 – Exhibit F deposition of Vaughn excerpts
== 243-07 – Exhibit G deposition of Murray excerpts
== 243-08 – Exhibit H deposition of Penon excerpts
== 243-09 – Exhibit I deposition of Dameron excerpts
== 243-10 – Exhibit J header says Johnson dep, actually OFAC draft
== 243-11 – Exhibit K Flight itinerary Rossi and Johnson 7/28/2014
== 243-12 – Exhibit L deposition of Dameron excerpts
== 243-13 – Exhibit M Affidavit of Rossi in support of 3pDef MSJ
== 243-14 – Exhibit N IH responses to 1st Rossi interrog excerpts
== 243-15 – Exhibit O deposition for IPH by Fogelman excerpts
== 245-01 – Exhibit 1 License Agreement 10.5 MB
== 245-02 – Exhibit 2 Term Sheet – AACT Ex. 17, Complaint Ex. B 2.0 MB
== 245-03 – Exhibit 3 Email Rossi/IH drafts of Term Sheet
== 245-04 – Exhibit 4 from deposition of Darden 11.5 MB
== 245-05 – Exhibit 5 from deposition of Vaughn 17.5 MB
== 245-06 – Exhibit 6 from deposition of Rossi 10.5 MB
== 245-07 – Exhibit 7 from deposition of JMP by Rossi 15.2 MB
== 245-08 – Exhibit 8 from deposition of Johnson 34.8 MB
== 245-09 – Exhibit 9 incorporation J.M. Chemical Products, Inc.
== 245-10 – Exhibit 10 from deposition of Johnson 19.3 MB
== 245-11 – Exhibit 11 email Rossi to Vaughn re customer
== 245-12 – Exhibit 12 from deposition of Leonardo by Rossi 21 MB
== 245-13 – Exhibit 13 from deposition of Bass 11.1 MB
== 245-14 – Exhibit 14 from deposition of Murray 17.3 MB
== 245-15 – Exhibit 15 plant data and expert disclosure of Murray
== 245-16 – Exhibit 16 FPL data
== 245-17 – Exhibit 17 IH-USQL Agreement Sept. 2013
== 245-18 – Exhibit 18 from deposition of West 15.0 MB
== 245-19 – Exhibit 19 from deposition of Fabiani 19.0 MB
== 245-20 – Exhibit 20 from deposition of Penon 11.2 MB
== 245-21 – Exhibit 21 emails Rossi about customer, was AACT Ex. 16
== 245-22 – Exhibit 22 emails IH, Cassarino, Rossi
== 245-23 – Exhibit 23 OFAC signed by Johnson
== 245-24 – Exhibit 24 email Rossi to Matthey re purchase 3/22/2015
== 245-25 – Exhibit 25 declaration of Darden
== 245-26 – Exhibit 26 Doral sublease: Leonardo to JMP
== 245-27 – Exhibit 27 emails Rossi-IH February 2015
== 245-28 – Exhibit 28 February 2015 emails Rossi-IH
== 245-29 – Exhibit 29 February communications Rossi-Johnson
== 245-30 – Exhibit 30 Bass business card
== 245-31 – Exhibit 31 deposition of Stokes 5.8 MB
== 245-32 – Exhibit 32 Rossi-Johnson emails
== 245-33 – Exhibit 33 Rossi-Bass emails
== 245-34 – Exhibit 34 July 2015 Rossi: Murray “cannot enter.”
== 245-35 – Exhibit 35 Vaughn to Johnson & Rossi about December visit, Johnson reply
== 245-36 – Exhibit 36 Murray questions for Penon, AACT Exhibit 5
== 245-37 – Exhibit 37 Fabiani-IH correspondence, February-April 2016 (AACT Ex. 21) 3.6 MB
== 245-38 – Exhibit 38 Murray to Fabiani April 2016
== 245-39 – Exhibit 39 Murray-Fabiani April-May 2016
== 245-40 – Exhibit 40 Fabiani-Murray April 2016
== 245-41 – Exhibit 41 IH Leonardo and USQL payments
== 245-42 – Exhibit 42 Declaration of Vaughn
== 247-01 – Exhibit 22 Cassarino (AEG) handwritten notes
== 247-02 – Exhibit 30 IH payments to Rossi and AEG
== 247-03 – Exhibit 31 2012 Tax Return Leonardo EID 90-0780933 2.9 MB
== 247-04 – Exhibit 32 2013 Amended return Leonardo EID 90-0780933 12.3 MB
== 247-05 – Exhibit 33 Rossi Personal Tax Return 1040NR 2013
== 248-1_Exhibit_1 Expert disclosure of Wong 2.9 MB
== 248-2_Exhibit_2 deposition of Wong
== 248-3_Exhibit_3 deposition for Leonardo by Rossi
== 248-4_Exhibit_4 deposition of Rossi
== 248-5_Exhibit_5 deposition for JMP by Rossi
== 248-6_Exhibit_6 supplemental expert report of Smith 2.1 MB
== 251-01 – Exhibit 23 (0207.23 was blank) Declaration of Vaughn
== 252-01 – Exhibit A Annesser to Pace 12/14/3015
== 252-02 – Exhibit B from Murray deposition
== 252-03 – Exhibit C expert disclosure of Murray
== 252-04 – Exhibit D expert report of Smith
== 252-05 – Exhibit E supplemental expert report of Smith 2.0 MB
== 252-06 – Exhibit F from deposition of Smith
== 253-01 – Exhibit 1 Italian law
== 253-02 – Exhibit 2 from Darden deposition
== 253-03 – Exhibit 3 from deposition for IPH by Fogleman
== 254-1 Exhibit A from deposition for IH by Vaughn
== 254-2 Exhibit B from deposition of Vaughn
== 254-3 Exhibit C from deposition of Vaughn
== 254-4 Exhibit D from deposition of Vaughn
== 254-5 Exhibit E from deposition of Darden
== 254-6 Exhibit F from deposition of Murray
== 256-01 – Exhibit 1 deposition for JMP by Rossi 15.2 MB file
== 256-02 – Exhibit 2 deposition of Darden 11.5 MB file
== 256-03 – Exhibit 3 deposition of Johnson 35.8 MB file
== 256-04 – Exhibit 4 deposition of Bass 11.1 MB file OCR of pp 110-121
== 256-05 – Exhibit 5 deposition of Vaughn 17.5 MB file
== 256-06 – Exhibit 6 deposition of Murray 17.3 MB file
== 256-07 – Exhibit 7 deposition for Ampenergo by Cassarino
== 262-01 Exhibit 1 Deposition for Industrial Heat by Vaughn
== 262-02 Exhibit 2 First Amendment to License Agreement
== 262-03 Exhibit 3 Email 2013 Rossi-IH re Validation Test ERV
== 262-04 Exhibit 4 DRV 2013 memo re Validation Test
== 262-05 Exhibit 5 Deposition of Darden
== 262-06 Exhibit 6 Penon Validation Test report
== 262-07 Exhibit 7 Deposition of Vaughn
== 262-08 Exhibit 8 Expert Report of Smith
== 262-09 Exhibit 9 Email Rossi to IH at startup of Doral power delivery
== 262-10 Exhibit 10 Deposition of Murray
== 262-11 Exhibit 11 Deposition of Fogleman
== 264-01 – Exhibit 1 Deposition of Rossi 4.2 MB
== 264-02 – Exhibit 2 Expert Report of Smith
== 264-03 – Exhibit 3 Deposition of Dameron
== 264-04 – Exhibit 4 Deposition for JMP by Rossi
== 264-05 – Exhibit 5 “What is a Megawatt?” from nrc.gov
== 264-06 – Exhibit 6 Expert Disclosure of Murray
== 264-07 – Exhibit 7 Deposition of Wong
== 264-08 – Exhibit 8 Deposition for JMP by Rossi
== 264-09 – Exhibit 9 Deposition of Penon
== 264-10 – Exhibit 10 Deposition of Fabiani
== 264-11 – Exhibit 11 IH-USQL Agreement 2013 3.8 MB
== 264-12 – Exhibit 12 8/2015 letter from Rossi to IH, 12/2015 reply Jones Day for IPH
== 264-13 – Exhibit 13 12/9/015 mail IH-Rossi/JMP re proposed 12/2015 visit, Johnson reply
== 264-14 – Exhibit 14 12/2017 mail Annesser (Rossi) to Pace (IH) re dispute and anticip. breach
== 264-15 – Exhibit 15 Declaration of Vaughn
== 264-17 – Exhibit 17 Rossi JONP posts April 6-18, 2017
== 264-18 – Exhibit 18 Penon Final Report 7.9 MB
== 264-19 – Exhibit 19 Deposition of Murray
== 264-20 – Exhibit 20 Deposition of Darden
== 276-01 – Exhibit 1 excerpt 4/20 discovery hearing transcript re spoliation
== 276-02 – Exhibit 2 deposition of Penon
== 276-03 – Exhibit 3 License Agreement
== 276-04 – Exhibit 4 email Lamacraft to Vaughn
== 276-05 – Exhibit 5 2.7 MB IHHI valuation as of May 13, 2015
== 278-1 Ex. 1 Darden to Rossi 2014-07-10 re term sheet
== 278-2 Ex. 2 Rossi to Darden 2014-07-11 revised sheet
== 278-3 Ex. 3 Rossi to Darden 2014-07-30 re confidentiality
== 278-4 Ex. 4 deposition for JMP by Rossi
== 278-5 Ex. 5 Vaughn to Johnson 2014-08-11 draft OFAC declaration
== 278-6 Ex. 6 deposition of Darden
== 278-7 Ex. 7 deposition of Bass
== 279-01 – Exhibit 1 4/23/2013 Rossi to Vaughn re Validation Test
== 279-02 – Exhibit 2 4/24/2013 Rossi to IH re VT
== 279-03 – Exhibit 3 deposition of Rossi
== 279-04 – Exhibit 4 5/5/2013 ERV report on Validation Test
== 279-05 – Exhibit 5 deposition of Penon
== 279-06 – Exhibit 6 Italian regulations
== 279-07 – Exhibit 7 2/18-2/20/2015 Penon – IH re test protocol
== 279-08 – Exhibit 8 deposition of Dameron
== 279-09 – Exhibit 9 deposition of Murray
== 279-10 – Exhibit 10 10 MB License Agreement
== 279-11 – Exhibit 11 3.8 MB Lugano Report
== 279-12 – Exhibit 12 9/10/2012 Rossi to Darden/Vaughn re Hydro Fusion test
== 279-13 – Exhibit 13 9/10/2012 Rossi to Darden/Vaughn re getting rid of “big clicense.”
== 279-14 – Exhibit 14 9/17/2012 Rossi to Darden re Agreement negotiations
== 279-15 – Exhibit 15 0/5/2012 Darden to Rossi re Agreement negotiations
== 283-01 – Exhibit 1 full transcript of Magistrate hearing 2/23/2017
== 283-02 – Exhibit 2 full transcript of Magistrate hearing 3/9/2017
== 283-03 – Exhibit 3 full transcript of Magistrate hearing 4/20/2017
== 283-04 – Exhibit 4 2/23/2016 Darden to Zalli/Uzi Shaya
== 283-05 – Exhibit 5 Levi declaration
== 283-06 – Exhibit 6 deposition of Darden
== 285-01 – Exhibit 1 Feb 2015 emails IH-Penon
== 285-02 – Exhibit 2 deposition for Leonardo Corp by Rossi
== 285-03 – Exhibit 3 deposition of Dameron
== 285-04 – Exhibit 4 deposition of Penon
== 285-05 – Exhibit 5 deposition of Rossi
== 285-06 – Exhibit 6 deposition for JMP by Rossi
== 285-07 – Exhibit 7 photo of steam pipe coming out of reactor container
== 285-08 – Exhibit 8 deposition of Wong
== 285-09 – Exhibit 9 expert disclosure of Murray
== 285-10 – Exhibit 10 expert report of Smith
== 285-11 – Exhibit 11 (14 previously) 12/14/2015 email Annesser to Jones Day
== 285-12 – Exhibit 12 12/9/2015 mail Vaughn to Rossi & Johnson
== 285-13 – Exhibit 13 12/9/2015 mail Johnson to Vaughn
== 285-14 – Exhibit 14 2/22/2016 Jones Day to Johnson re default and security
== 285-15 – Exhibit 15 full transcript 4/20 Magistrate hearing
== 285-16 – Exhibit 16 Order from 4/20 hearing (DE 266)
== 297-01 – Exhibit 1 April 20 Discovery hearing full transcript.
== 297-02 – Exhibit 2 1/11/2016 USPTO correspondence re Rossi patent
== 297-03 – Exhibit 3 Murray queries for Penon re conv. 2/16-17/2016
== 297-04 – Exhibit 4 deposition of Penon
== 297-05 – Exhibit 5 Fabiani Plant data
== 297-06 – Exhibit 6 joint trial stipulation ¶¶ 1-2.
== 299-01 – Exhibit 1 deposition of Fabiani
== 299-02 – Exhibit 2 5/12/2017 declaration of Murray
== 299-03 – Exhibit 3 2/23/2016 email Fabiani to Vaughn
== 299-04 – Exhibit 4 3/22 and 4/1/2016 Murray to Fabiani
== 299-05 – Exhibit 5 3/21/2017 declaration of Vaughn
== 305-01 – Exhibit 1 full transcript of April 20 hearing
== 307-01 – Exhibit A deposition of Darden
== 307-02 – Exhibit B declaration of Uzi Shaya
Documents presented without attestation.
== 0001-1_exhibit_a 2015 Rossi US Patent
== 0001-2_exhibit_b License Agreement
== 0001-3_exhibit_c 1st amendment to License Agreement
== 0001-4_exhibit_d 2nd Amendment to License Agreement
06/29/2016 0021-0_darden_interested_parties
06/30/2016 0022-0_rossi_interested_parties
== 0029-1_exhibit_1 Official critique of Rossi patent
== 0029-2_exhibit_2 Official critique of Rossi patent
== 0029-3_exhibit_3 Six Cylinder Unit photos
== 0029-4_exhibit_4 Rossi blog posts August and September 2015
== 0029-5_exhibit_5 Queries from Murray to Penon
== 0029-6_exhibit_6 list of patent applications
== 0029-7_exhibit_7 Assignment of License from IH to IPH
== 0029-8_exhibit_8 April 2013 Leonardo Certificate
== 0029-9_exhibit_9 Rossi email re Validation Test and “Health Office.”
== 0029-10_exhibit_10 http://arxiv.org/abs/1305.3913 … the “independent professors” Ferrara report
== 0029-11_exhibit_11 Agreement with USQL (Fabiani)
== 0029-12_exhibit_12 Rossi email September 10, 2012 re Hydro Fusion
== 0029-13_exhibit_13 Rossi email Mon, Sep 10, 2012 re European licensees
== 0029-14_exhibit_14 Levi et al, Lugano paper
== 0029-15_exhibit_15 Articles of Incorporation, J.M. Chemical Products, Inc.
== 0029-16_exhibit_16 Rossi email July 05, 2014 re renting to JM in Florida
== 0029-17_exhibit_17 Term Sheet for rental of 1 MW unit to JMC
== 0029-18_exhibit_18 JM Products reports of power used
== 0029-19_exhibit_19 Rossi email Jul 13, 2015 refusing access to IH engineer
== 0029-20_exhibit_20 Original was a large pdf, this is a reduced size jpg of the Bass business card
== 0029-21_exhibit_21 Fabiani emails (2016) 2/23, 4/6, and 4/14, replies of Joseph Murray, 4/26, 5/16
== 0029-22_exhibit_22 Cook and Rossi paper
== 0029-23_exhibit_23 Jones Day (IH) letter to Annesser (Rossi) re patent assignment. 2/7/2016
== 0029-24_exhibit_24 Rossi blog posts Aug 18, 2015 – Sep 13, 2015 (duplicates Exhibit 4?)
== 0029-25_exhibit_25 Rossi blog post April 14, 2016, claiming new sales to Customer of 1-year test.
The exhibits 1-25 were repeated in subsequent amended Answers, only new documents are shown here:
== 0030-26_exhibit_26 photos of warehouse and customer area
== 0050-27_exhibit_27 IPH assignment from IH
12/20/2016 0093.0_JMP_interested_parties
12/20/2016 0094.0_USQL_interested_parties
== 0108.1_Patent Exhibit A
== 0108.2_Rossi_email_2-5-2015 Exhibit B
== 0108.3_Rossi_email_3-17-2015 Exhibit C
== 0108.4_Darden_email_4-10-2015 Exhibit D
== 0128.1_Exhibit_1 part of Penon Report?
== 0128.2_Exhibit_2 JMP electrical billing
== 124.29_Fabiani_contract_renewal Exhibit 28
== 124.30_Fabiani_email_re_contract Exhibit 29
== 0129.1_Exhibit_A Chart showing daily utility usage vs Penon and Fabiani
== 0167.2_Exhibit_1 Email from Darden to Sloan, 3/7/2014 (OCR’d version)
== 0167.3_Exhibit_2 Lugano report, scan filed, link here is to original
== 0167.5_Exhibit_4 Declaration of Levi
== 0167.6_Exhibit_5 Email from Darden to Zalli and Uzi
== 0167.7_Exhibit_6 Email Weaver -> Bo Hoisted -> Levi -> Rossi
== 0167.8_Exhibit_7 Deposition of Dewey Weaver
== 0194.04_Exhibit_4 Discussion of “megawatt” from NRC.
== 0194.11_Exhibit_11 3.8 MB file USQL consulting agreement
== 0194.12_Exhibit_12 December 4, 2015 email Pace to Annesser
== 0194.13_Exhibit_13 emails Rossi to IH, August 3, 2015, Vaughn to Rossi and Johnson, December 4, 2015, Pace to Annesser, December 9, 2015, Johnson reply, and Pace to Johnson, February 22, 2016.
== 0194.14_Exhibit_14 email Annesser to Pace, December 14, 2015
== 0194.16_Exhibit_16 unidentified data
== 0197.03_Exhibit_3 7.7 MB file Penon report
== 0215.05_Exhibit_E 2.6 MB file License Agreement
== 0215.06_Exhibit_F 2013 mails Rossi – Vaughn re Validation Test and ERV
== 0226.1_Attachment_1 Darden to Zalli and Uzi, previous 167.6
== 0228.3_Exhibit_C copy of Zalli Jaffe’s biography
