Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :04-cv-01534-KAJ Document 15 Filed 04/12/2005 Page 1 of 3
IN TIIE UNITED STATES DISTRICT COURT
IN AND FOR T IIE DISTRICT OF DELAWARE
MARTIN DURANT, :
Plaintiff, C.A. NO. 04-1534 (KAJ)
v.
: JURY TRIAL DEMANDED
PERFECT CARE NURSES, INC., :
Defendant.
PLAINTIFF’S RULE 26ga} PRE-DISCOVERY DISCLOSURES
Plaintiff] Martin Durant, by and through his undersigned attorney, hereby
exchanges the following Pre—Discovery Disclosures, pursuant to Fed. R. Civ. P. 26(a)(l).
I. The name and, if known, the address and telephone number of each individual
likely to have discoverable information relevant to disputed facts alleged with
particularity in the pleadings, identifying the subjects of the information.
ANSWER:
l. Witness, Mr. Simon A. Ewobor, President of Perfect Care Nurses, Inc.,
who is familiar with the daily operations of Perfect Care and Plaintiff sj ob
responsibilities, and payroll records. .
2. Plaintifi Mr. Martin Durant who can be reached through. his attorney.
4. Plaintiff may identify additional witnesses in the future.
5. Plaintiff also reserves the right to call any of Defendant’s witnesses,
including those indicated in Defendant’s Rule 26(a) Initial Disclosures.
II. A copy ot, or a description by category and location of, all documents, data
compilations, and tangible things in the possession, custody, or control of the party that
are relevant to disputed. facts alleged with particularity in the pleadings.
ANSWER:
I. Copies of various pay stubs Plaintiff received from Defendant.

Case 1:04-cv-01534-KAJ

Document 15

Filed 04/12/2005

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Case 1:04-cv-01534-KAJ

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Case 1:04-cv-01534-KAJ

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