Reed Simpson Testifying Computer Expert Witness, Computer Consultant Data Base Expert.

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REED F. SIMPSON
BS, MBA, CDP , REGISTERED INVESTMENT ADVISOR
Specialist in Computer and Internet Technology,
Software Project Management, Software Selection and Implementation


Computer/Legal Consultants, Inc.
5267 West Highland Drive
Suite 100
Coeur d'Alene, ID 83814
(208) 765-9181
reed@computerlegal.com
www.computerlegal.com

Updated: Monday, October 22, 2007

Professional Summary

Mr. Simpson has over 39 years experience as a specialist in computer and Internet technology with a focus on project management, software systems selection and implementation, data base design and computer network systems architecture. He has been an independent consultant to industry and the legal profession since 1980. Mr. Simpson is an experienced legal consultant and expert witness with testimonial experience at deposition and trial. A summary of Mr. Simpson’s expertise includes:

Expertise
Computer Software Systems Implementation Software Selection Software Implementation Project Management Enterprise Resource Planning (ERP) Systems Department Of Defense Earned Value Management Systems Internet Data Base Design Internet Technology MIS Planning & Execution Internet Service Provider (ISP)	Relational Database Management Systems Web Site Design Web Site Operation and Management Micro-Computer hardware Architectures Embedded Microcomputer Systems Network Systems Architecture County Welfare Processing Systems

Industry Applications
Aerospace Program Management Systems Earned Value Management Systems Enterprise Resource Planning (ERP) Systems Material Control MRP Shop Floor Control Data Collection Financial Budgeting Estimating Quality Assurance Commercial Banking Systems Computer Aided Design Computer Aided Manufacturing Fire District Information Systems	Consumer Goods Packaging and Distribution County Election Systems County Public Information Publication (Internet) County Welfare Data Base Information System Engineering Time-Sharing Systems Hospital Pharmacy Accounting Law Office Automation Newspaper Publishing Property Mapping Systems Medical Billing Solid Waste Billing and Accounting Stock Price Technical Analysis TV Production Company Cost and Royalty Accounting
Operating Systems:
IBM OS/MVS, VM IBM/Microsoft DOS MAC/OS Novell Netware TRS/DOS Unix	Windows 95, 98 Version 1, 2, 3, 3.11 WinCE Windows 2000 Windows 2000 Advanced Server Windows NT Windows ME Windows XP
Data Base/Data Access:
BDAM Btrieve C-ISAM Dbase Filemaker FoxPro IBM DL/1 IBM IMS IBM DB2 Indexed Sequential Access Method (ISAM) Informix	Lotus Approach Magic PC Microcomputer Data Base System (MDBS) Microsoft Access Microsoft SQL Server Oracle Paradox Progress QPro4 Rbase (Microrim) Various Flat File Databases
Programming Languages:
Access Basic Active Server Pages (ASP) Basic C, C++ Cobol Fortran Front Page J Script HTML/DHTML Java	Machine and Assembly Language - Various processors Numerous macro and command languages Pascal Perl VB Script Visual Basic Visual Basic for Applications (VBA)
Hardware:
Engineering workstations - many manufacturers IBM Mainframe Network server - many manufacturers Multi Processor High Reliability Raid Storage PC Workstations - many manufacturers	Networking: Arcnet Ethernet Communications - Dial-up, ISDN, Leased line, T-1 Router, Firewall, Switches, Hubs. Network Data Backup - DLT High Capacity Library.

Education

B. S. - Business Administration - California State Polytechnic University
M.B.A California State Polytechnic University
Masters Thesis: Technical Analysis of Stock Market Trends
Post Graduate-Mathematics - California State University - Los Angeles
Post Graduate-Quantitative Analysis - UCLA
Post Graduate-University Of West Los Angeles Law School
Programming Languages
Computer Operating Systems
Computer Networking
Computer Hardware
Applications Software

Professional Experience

From:	1980	Computer/Legal Consultants, Inc. and Chelsea Group, Inc.
To:	Present
Position:		Vice President
Computer/Legal Consulting, Inc. focuses on consulting in the areas of project management and litigation support, including expert witness in computer issues. The Chelsea Group Inc., focuses on consulting requirements involving computer management. Responsibilities include advising clients in the planning, selection, acquisition and installation of computerized systems to support business needs. The Chelsea Group has served clients in many industry groups. Specific areas of expertise include: Internet web site development, maintenance and operation Web page design, navigation structure, link management and data file/content delivery and download Internet Data Base design, development and integration with "data driven" Web sites Internet email server design, setup, installation and operation Internet user setup, system security, performance and "spam" management Computer hardware/software selection, acquisition, contract negotiation and installation management Computer network systems design, specification, selection, acquisition and support Business contract strategy and negotiation Management Control Systems Planning/Evaluation MIS long-range planning and execution Systems design/programming of manufacturing, financial, project management, quantitative analysis and decision support systems Business planning and expansion strategy Financial Analysis and Cost control strategy

From:	1973	HR Textron, Inc. - An Aerospace division of Textron, Inc.
To:	1980
Position:		Director, Management Information Services General Manager - Apco Products Division - Aerospace Fuel and Pneumatic Division Director, Long Range Planning and Corporate Development
Director, Management Information Services - Responsibilities included: Division data processing operations Systems development and planning Engineering design computing systems Division print shop Division data base development Support other Textron Divisions with Program/Project management systems requirements. Textron Computer Technology Consultant General Manager - Apco Products Division - Aerospace Fuel and Pneumatic Division - Responsibilities included: Profit and Loss responsibility for division operations. Operations included Marketing, Engineering, Manufacturing and Finance. Director, Long Range Planning and Corporate Development - Responsibilities included: Division Strategic Planning Growth strategy development and coordination Division acquisition and divestiture strategy Product and service group charters Technology Assessment Attend Classified U.S. Military briefings

From:	1972	Coca Cola Bottling Company Of Los Angeles
To:	1973
Position:		Manager, Corporate Data Processing
Responsible for Corporate data processing systems development, computer operations, software/hardware selection and implementation..

From:	1965	General Dynamics, Pomona Division
To:	1973
Position:		Manager, Financial and Program Management Systems
Manager, Financial and Program Management Systems - Responsible for: Managing the planning, development, programming and support of all Pomona Division Financial Systems. Planning, development, programming and support of all Pomona Division Program Management Systems. Assist other General Dynamics Divisions with Project Management systems projects Special project assignment to develop data base systems requirements for Pomona Aerospace Division Operations.

Litigation Support Experience

*Expert Engagement:*
Type Of Matter:	Aircraft Accident
Case Name:	American Airlines v. Honeywell, Jeppesen. Aircraft Accident of December 20, 1995 near Cali Columbia - American Airlines Flight 965. Ref: [100]
Jurisdiction:	Florida-Southern District
Client:	American Airlines
Nature Of Case:	Airline accident with issues concerning the flight control computer, the data base contained within and the many processes involved in creating the data base. Several companies and many computer systems are involved.
Services Provided:	Consulting Technical expert. Analyze Flight management software development, flight data base contents and development. Review electronic records including email, CDROM, data base backup, problem logs and certification data. Analyze Flight Management Computer software version history and program source code.
Law Firm:	Sullivan, Johnson & Manfredi-Los Angeles, CA
Disposition:	Complete June 2000.

*Expert Engagement:*
Type Of Matter:	Class Action
Case Name:	Miller - Class Action v. Bank Of America Ref: [150]
Jurisdiction:	San Francisco Superior Court
Client:	Miller (Class Action)
Nature Of Case:	Miller (Class Action) claims that Bank Of America did not properly process Checking accounts with Social Security Direct Deposit activity. The class-action case, filed 5 1/2 years ago, centers on allegations that Bank of America collected some customer service fees by siphoning money from direct deposit accounts set up to receive Social Security benefits.
Services Provided:	Designated Expert. Expert Declaration. Testimony at Trial. Damages Expert Designated Technical Expert concerning production of computerized account records. Design, build and operate relational data base system to analyze 50 million records produced in electronic form by Bank Of America.
Law Firm:	The Sturdevant Law Firm-SF
Disposition:	Complete February, 2004.

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Department 56 v. Arthur Anderson Ref: [200]
Jurisdiction:	Minnesota, Hennepin County
Client:	Arthur Anderson LLP
Nature Of Case:	Department 56 claims that Arthur Anderson committed fraud while assisting Department 56 in the selection and implementation of J. D. Edwards ERP software system.
Services Provided:	Designated Expert. Expert Report. Litigation Support. Review software selection process. Review project management. Review policy implications of new software system implementation.
Law Firm:	Bartlit Beck Herman Palenchar & Scott-Chicago, IL
Disposition:	Complete February 2002

*Expert Engagement:*
Type Of Matter:	Software Systems Development
Case Name:	Tri Valley Growers v. Oracle Corporation Ref: [300]
Jurisdiction:	San Francisco Superior Court
Client:	Tri-Valley Growers
Nature Of Case:	Tri Valley Growers purchased a Consumer Packaged Goods (CPG) software system from Oracle Corporation. TVG alleges that the software was defective, did not meet its needs and was never completely installed.
Services Provided:	Designated Expert. Expert Report. Deposition Testimony. Consulting Technical Expert. Review and evaluate Oracle management decision making process, development planning and project management.
Law Firm:	Dorsey & Whitney-Minneapolis, MN
Disposition:	Complete January 2002

*Expert Engagement:*
Type Of Matter:	Patent Infringement
Case Name:	Orion IP V. Staples, Inc., et al Ref: [350]
Jurisdiction:	US District - Marshall TX.
Client:	Toyota, Harley Davidson, Home Depot
Nature Of Case:	Orion IP Claims Infringement of U.S. Patent 5,367,627 COMPUTER-ASSISTED PARTS SALES METHOD - Johnson
Services Provided:	Designated Expert. Expert Report. Deposition Testimony
Law Firm:	Vinson & Elkins, McDermott Will & Emery, Fulbright & Jaworski
Disposition:	Complete March 2006

*Expert Engagement:*
Type Of Matter:	Service Mark Infringement
Case Name:	Farmers Group, Inc. v. Guerrero Ref: [355]
Jurisdiction:	U.S. District Court-Washington - Eastern District
Client:	Guerrero, Rene
Nature Of Case:	Farmers Insurance Group alleges that an Internet gripe site maintained by Guerrero (1) Service Mark Infringement. (2) Unfair Competition. (3) Service Mark Dilution. (4) Unfair Competition And Unfair Or Deceptive Acts.
Services Provided:	Designated Expert Expert Report
Law Firm:	Preston, Gates & Ellis-Spokane
Disposition:	Complete January 2006

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Westlake Chemical Corporation and Westlake Management Services, Inc. v. Oracle Corporation, Experio Solutions Corporation and Grant Thornton LLP. Ref: [400]
Jurisdiction:	Texas-District Court of Harris County
Client:	Westlake Chemical Corporation
Nature Of Case:	Westlake claims that Oracle, Experio and Grant Thornton were to blame for the failed implementation of Oracle eProcurement and SAP Connector integration software.
Services Provided:	Designated Expert. Expert Report.
Law Firm:	Doyle, Restrepo, Harvin & Robbins-Houston
Disposition:	Complete April 2003

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Pioneer-Standard Electronics, Inc. v. CAP Gemini America, Inc. Ref: [450]
Jurisdiction:	U.S. District Court-Ohio-Northern District
Client:	CAP Gemini America, Inc.
Nature Of Case:	Pioneer claims that CAP Gemini contributed to a failed IMI ESS - Oracle Financial Software Selection and Integration. Pioneer Standard claims software was defective, did not meet its needs and was implemented improperly.
Services Provided:	Designated Technical Expert. Designated Damages Expert. Expert Report. Deposition Testimony. Testimony at Trial
Law Firm:	Shearman & Sterling-NYC
Disposition:	Complete December 2003.

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Priority Healthcare Corporation v. Deloitte & Touche LLP. Ref: [470]
Jurisdiction:	Florida Circuit - Ninth District
Client:	Deloitte & Touche LLP
Nature Of Case:	Priority claims faulty performance by Deloitte during a Computer Software Selection and implementation involving Oracle software and Custom developed applications.
Services Provided:	Designated Expert Expert Analysis
Law Firm:	Holland & Knight-Miami
Disposition:	Complete September 2005

*Expert Engagement:*
Type Of Matter:	Warehouse Software Implementation
Case Name:	TigerDirect, Inc. and Systemax V. Manhattan Associates, Inc. Ref: [473]
Jurisdiction:	Florida-Southern District
Client:	TigerDirect, Inc. and Systemax, Inc.
Nature Of Case:	Manhattan Associates contracted with TigerDirect for the purchase and installation of a Warehouse Management System designed to handle TigerDirect high order and shipping volumes. Tiger claims that the Manhattan Warehouse for Microsoft Windows system was not capable of supporting the TiderDirect warehouse operation after the system went live.
Services Provided:	Designated Expert. Expert Report. Deposition Testimony
Law Firm:	Holland & Knight - Tampa
Disposition:	Complete February 2007

*Expert Engagement:*
Type Of Matter:	Software Systems Development
Case Name:	Evangelical Lutheran Church in America Board of Pensions V. Spherion Pacific Workforce Ref: [475]
Jurisdiction:	US District Court-Minnesota
Client:	Evangelical Lutheran Church in America Board of Pensions
Nature Of Case:	The Board of Pensions contracted with Spherion to develop a software system to replace a legacy system. The Board of Pensions claims that Spherion produced a software system that was of little or no value and was a failed software implementation.
Services Provided:	Designated Expert. Expert Report.
Law Firm:	Dorsey & Whitney-Minneapolis, MN
Disposition:	Complete May 2006.

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Answerthink v. Del Monte Fresh Produce Company Ref: [480]
Jurisdiction:	Florida Circuit Court-Miami
Client:	Del Monte Fresh Produce Company
Nature Of Case:	Answerthink was retained by DelMonte to implement Oracle applications software in the United States and several other countries. DelMonte claims that Answerthink materially breached the agreements.
Services Provided:	Designated Expert
Law Firm:	Holland & Knight-Miami
Disposition:	Pre-Trial Discovery

*Expert Engagement:*
Type Of Matter:	Computer Hardware/Software Development
Case Name:	Hewlett-Packard Company V. Factory Mutual Insurance Company Ref: [500]
Jurisdiction:	U.S. District Court - NY
Client:	Factory Mutual Insurance
Nature Of Case:	HP claims significant loss due to sabotage by a former employee. Factory Mutual disputes the loss claim.
Services Provided:	Consulting Technical expert.
Law Firm:	Robins, Kaplan, Miller & Ciresi
Disposition:	Complete May 2004

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Computer Horizons v. Spearhead Consultants and SAP America, Inc. Ref: [600]
Jurisdiction:	New York-Supreme Court - NY County
Client:	Computer Horizons Corp.
Nature Of Case:	Computer Horizons purchased SAP software system which was to be customized and installed by Spearhead Systems. Computer Horizons claims software was defective, did not meet its needs and was implemented improperly.
Services Provided:	Designated Expert. Expert Report. Consulting Technical Expert. Evaluate system requirements, technical structure, data interface, data base structure and system integration structure.
Law Firm:	Proskauer Rose-New York City, NY
Disposition:	Complete March 2001.

*Expert Engagement:*
Type Of Matter:	Theft Of Software Trade Secrets
Case Name:	United Computer Systems, Inc. v. AT&T and Lucent Technologies, Inc. Ref: [700]
Jurisdiction:	California-American Arbitration Association-LA
Client:	AT&T and Lucent Technologies, Inc
Nature Of Case:	Computer software system, claims of capabilities and performance.
Services Provided:	Designated Expert. Testimony at Trial. Analysis of computer system, source code and underlying file structure and operation. Review data base structure.
Law Firm:	Orrick, Herrington & Sutcliffe-Los Angeles, CA
Disposition:	Complete June 1999.

*Expert Engagement:*
Type Of Matter:	Theft Of Software Trade Secrets
Case Name:	G5 Technologies, Inc. v. International Business Machines Corporation Ref: [750]
Jurisdiction:	U.S. District Court - NY
Client:	G5 Technologies
Nature Of Case:	G5 claims that IBM used G5 Internet E Commerce Trade Secrets and Confidential Information for Its own benefit and to the detriment of G5. G5 claims that IBM commercialized G5's VCMS as embodied in IBM's Websphere products.
Services Provided:	Designated Expert.
Law Firm:	Garvey Schubert Barer-New York
Disposition:	Complete December 2005

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	University of Quebec v. SAP Canada Inc. Ref: [800]
Jurisdiction:	Canada-Montreal Arbitration Tribunal
Client:	University of Quebec
Nature Of Case:	Failed SAP software implementation claimed by University of Quebec.
Services Provided:	Designated Expert. Expert Report. Testimony at Trial.
Law Firm:	Woods & Partners-Montreal, Canada
Disposition:	Complete August 2003

*Expert Engagement:*
Type Of Matter:	Medical Billing Software Implementation
Case Name:	State Of Iowa vs. InfoSys, Inc. Ref: [860]
Jurisdiction:	Iowa District Court-Polk County
Client:	InfoSys, Inc.
Nature Of Case:	The State Of Iowa Department of Human Services claims that InfoSys provided a flawed system to perform Medical billing and processing.
Services Provided:	Designated Expert.
Law Firm:	Holland & Knight-Chicago
Disposition:	Completed January 2005

*Expert Engagement:*
Type Of Matter:	State Medicaid Software System Implementation
Case Name:	Texas Department Of Health v. EDS-National Heritage Insurance Company Ref: [870]
Jurisdiction:	AAA - Dallas, TX
Client:	EDS-National Heritage Insurance Company
Nature Of Case:	Texas Department Of Health claims that National Health/EDS improperly billed development and other costs. Determination of substantial completion of installed computer system. Status and significance of CMS audit of State Medicare/Medicaid System.
Services Provided:	Designated Expert. Expert Report. Deposition Testimony. Trial Testimony
Law Firm:	Hughes & Luce-Dallas
Disposition:	Complete October 2004.

*Expert Engagement:*
Type Of Matter:	ERP Software Implementation
Case Name:	Ocean Garden Products, Inc. v. IBM Global Services, a Division of International Business Machines Corporation Ref: [900]
Jurisdiction:	US District Court-California Southern District
Client:	IBM Corporation
Nature Of Case:	Ocean Garden Products claims Breach of Contract and Fraud by IBM during the selection and implementation of the QAD ERP software to replace a non-Y2K compliant legacy system.
Services Provided:	Designated Expert. Expert Report. Technology consultant.
Law Firm:	Quinn Emanuel Urquhart Oliver & Hedges-Los Angeles, CA
Disposition:	Complete August 2003

*Expert Engagement:*
Type Of Matter:	Web Site Development
Case Name:	Uncle Henry�s Inc. v. Plaut Consulting Inc. and Edgewing, a Division of Plaut Consulting, Inc. Ref: [1000]