HomeMy WebLinkAbout2016CV1308 - FTN - FORT COLLINS V. CITY OF FORT COLLINS - 045 - PLAINTIFF'S WITNESS LISTIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 16-cv-1308
FREE THE NIPPLE – FORT COLLINS, an unincorporated association,
BRITTIANY HOAGLAND, and
SAMANTHA SIX,
Plaintiffs,
v.
CITY OF FORT COLLINS, COLORADO,
Defendant.
______________________________________________________________________________
PLAINTIFFS’ WITNESS LIST
1
______________________________________________________________________________
Witnesses denoted with an asterisk “*” are “will call” witnesses. All other witnesses are
“may call.”
1. Brittiany Hoagland*. Ms. Hoagland will testify regarding her membership in
Free the Nipple Fort Collins and the organization’s mission, her experience leading up to, and
after, the passage of the modified Section 17-142 in the summer and fall of 2015, the effect of
Section 17-142 on her personally, and her desire to stand topless at public places in Fort Collins,
Colorado. Estimated time for direct examination: .75 hours.
2. Samantha Six*. Ms. Six will testify regarding her membership in Free the
Nipple Fort Collins, her experience leading up to, and after, the passage of the modified Section
17-142 in the summer and fall of 2015, the effect of Section 17-142 on her personally, and her
1 Plaintiffs reserve the right to amend this witness list prior to the hearing and trial.
Case 1:16-cv-01308-RBJ Document 45 Filed 12/16/16 USDC Colorado Page 1 of 2
desire to stand topless at public places in Fort Collins, Colorado. Estimated time for direct
examination: .75 hours.
3. Ray Martinez. City Councilor Ray Martinez will testify regarding the legislative
history of Section 17-142 and the governmental interest served by Section 17-142. Estimated
time for direct examination: .75 hours.
4. Tomi-Ann Roberts. Dr. Tomi-Ann Roberts is an expert in psychology and
gender studies; she is currently the chair of the department of psychology at Colorado College.
She will testify regarding the historical implications of female toplessness, the real vs. perceived
differences between the male and female breast, the positive and neutral effects of viewing
female toplessness by children, the negative effects of criminalizing female toplessness on
women, and objectification theory and its intersection with the criminalization of female
toplessness. Estimated time for direct examination: 1 hour.
Dated this 16
th
day of December, 2016.
KILLMER, LANE & NEWMAN, LLP
s/ Andy McNulty
___________________________
David A. Lane
Andrew McNulty
1543 Champa Street, Suite 400
Denver, CO 80202
(303) 571-1000
(303) 571-1001 (fax)
dlane@kln-law.com
amcnulty@kln-law.com
Counsel for Plaintiffs
Case 1:16-cv-01308-RBJ Document 45 Filed 12/16/16 USDC Colorado Page 2 of 2