Case: 1:13-cv-01297 Document #: 30-6 Filed: 05/16/13 Page 1 of 4 PageID #:150

EXHIBIT F

Case: 1:13-cv-01297 Document #: 30-6 Filed: 05/16/13 Page 2 of 4 PageID #:151

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ROBERT ALMBLAD, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) )

v.

No. 13 -cv-1297

SCOTSMAN INDUSTRIES, INC., and KEVEN FINK, Defendants.

PLAINTIFF ROBERT ALMBLADS INITIAL DISCLOSURES PURSUANT TO FRCP RULE 26(a)(1)(A) Now comes the plaintiff, Robert Almblad, and pursuant to Federal Rule of Civil Procedure 26(a)(1)(A), submits his initial disclosures. (A)(i) The hereinafter listed individuals are likely to have discoverable information on the subjects hereinafter specified: Robert Almblad, 1137 Marine Drive, Tarpon Springs, FL 34689 Mr. Almblad, the plaintiff herein, has discoverable information on all subjects at issue including the design and design flaws of Scotsman Industries Commercial Ice Machines and comparable machines of other manufacturers. Mr. Almblad has information regarding tests for air flow contamination within commercial ice machines and how his inventions prevent such air flow. Mr. Almblad has information regarding the monetary damages he has suffered because of the defamatory statements complained of herein including lost profits, lost opportunities and damage to his reputation.

David McCulloch, (c/o Scotsman Industries, Inc.) Mr. McCulloch is the former CEO of Scotsman and is likely to have information regarding the design and design flaws of Scotsman ice machines. He is also likely to have information regarding testing of air flow in Scotsman ice machines and regarding Robert Almblads findings regarding air flow contamination. Mr. McCulloch is also likely to have knowledge regarding the profit and/or losses of Scotsman Industries during relevant periods. He shall also be knowledgeable regarding the impact and potential impact of Robert Almblads inventions upon the potential sale of Scotsman Industries. He is likely to have knowledge regarding conversations had with Manitowoc Ice management before and after the U.S.

Case: 1:13-cv-01297 Document #: 30-6 Filed: 05/16/13 Page 3 of 4 PageID #:152

Department of Justices keep separate orders as it would relate to air flow contaminate problems common to the commercial ice machines of Scotsman, Manitowoc and other ice machine manufacturers. Kevin Fink, defendant herein (c/o Scotsman Industries, Inc.) Mr. Fink is likely to have the same information and knowledge as recited above relating to Dave McCulloch. Matt Allison (c/o Scotsman Industries, Inc.) Mr. Allison is likely to have the same information and knowledge as recited above relating to Dave McCulloch, and in addition, Mr. Allison is likely to have had discoverable conversations with Daryle Erbs regarding Robert Almblads technology. Dave Wrench (c/o Scotsman Industries, Inc.) Mr. Wrench is expected to have information recited above related to David McCulloch. Rick Caron, Lee Wichlacz, Jan Jaferian, Dean Landeche, Darlye Erbs, (c/o Manitowoc Ice, Manitowoc, Wisconsin) It is believed that all of the aforementioned individuals would have knowledge on the same subject matters as recited above relating to Mr. David McCulloch. It is also expected that Mr. Erbs is likely to have knowledge of discoverable conversations he had with Mr. Matt Allison of Scotsman Industries, Inc. regarding Robert Almblads technology. John Broadbent (372 Garfield Street, Denver Colorado, Phone: 720-273-5737) Mr. Broadbent is likely to have information and knowledge regarding all engineering issues relating to air flows in the commercial ice machines of Scotsman Industries Inc., Manitowoc Ice and other commercial ice machine manufacturers. Mr. Broadbent is likely to have information regarding the financial status of Scotsman Industries Inc. at relevant times. He is also likely to have knowledge regarding testing conducted because of Robert Almblads findings related to air flow contamination of ice. Further, Mr. Broadbent is likely to have knowledge regarding the economic losses and damage to reputation suffered by Robert Almblad. Mike Kohler (NSF World Headquarters, 789 N. Dixboro Rd., Ann Arbor, MI 48105) Mr. Kohler is expected to have knowledge of conversations with David McCulloch and others of a collective effort to publicly deny the existence of defective airflows in ice machines and blame Robert Almblads character in order to increase or maintain the profitability of ice machines and NSF. Thomas Moseley (The Moseley Group, 31 Hayward St., Franklin, MA 02038) Mr. Moseley is expected to have information recited above related to David McCulloch. Luciano Berti, CEO Ali Group (Champion, an Ali Group Company, 3765 Champion Blvd.Winston-Salem, NC 27105) Mr. Berti is likely to have the same information and knowledge as recited above relating to David McCulloch. 2

Case: 1:13-cv-01297 Document #: 30-6 Filed: 05/16/13 Page 4 of 4 PageID #:153

The plaintiff reserves the right to supplement this disclosure as further information is obtained during discovery. (A)(ii) Documents, Electronic Stored Information and Tangible Things The plaintiff is possessed of those documents identified in a letter dated May 1, 2013 to defense counsel attached hereto as Exhibit A. The plaintiff has information stored on a hard drive that includes various correspondence, engineering drawings, patent searches, personnel records, relevant anti-trust research and correspondence and miscellaneous other business data. Robert Almblad is also possessed of raw data compiled during testing conducted in regard to air flow contamination in commercial ice machines. He is also possessed, in the nature of tangible things, with commercial ice machines of Scotsman Industries, Inc. and Manitowoc Ice and dispensers relating to same. He is possessed of those devices described in his patent applications which are a matter of public record, some of which patent information has been previously provided to defense counsel. Mr. Almblad is also possessed of instruments employed to measure air flow in commercial ice machines. (A)(iii) Computation of Damages/Damage Calculations The plaintiff is of the belief that there are approximately 3 million commercial ice machines with a design defect allowing for air flow causing contamination of ice at the time of its use. The plaintiff asserts that his inventions eliminate that air flow problem, and that it had been his expectation that he would be able to license his invention at $300 per year. It is the plaintiffs belief that he would have been able to license more than one million of his devices that would have eliminated the aforesaid contamination. The plaintiff expects to refine his damage calculations once sufficient data is available to permit for an analysis by a forensic economist. The plaintiff also believes that the statements of defendants constitute defamation per se with all the presumptions of damages arising therefrom. Respectfully submitted, /s/ Nicholas J. Motherway Motherway & Napleton, LLP Attorneys for Plaintiff 100 West Monroe Street, Suite 200 Chicago, IL 60603 (312) 726-2699 nmotherway@mnlawoffice.com