Free Response to Discovery - District Court of Delaware - Delaware

Case 1 :04-cv-01530-JJF Document 6 Filed O3/07/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT
OF DELAWARE
]31'O SB,
JOHN S. SHIPLEY, : CA. N0. 04-1530 JJP
I · : Jury Trial Demanded
Plaintiis, 2
Vs. i
J B & F TOWING COMPANY and _ :
owNERs, A business organized site ;
Existing under the laws ofthe United : ___
States of America :
448 oid Aspen Rd :
"
New Castle De, 19720 2 cn
s W " I
Defendants :
First Set 0fInterr0 s - ·.; .». . nts.
to the Defendant
I. On what date did you give John S. Shipley notice that you were going to tow his
car from his private property?
II. Produce a copy of the notice allegedly given to John S. Shipley advising that B &
F Towing Company was going to take his private property.
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Case 1:04-cv-01530-JJF Document 6 Filed O3/07/2005 Page 2 of 3
HI. What was the reason that you, B & F Towing Company, removed John S.
Shipley’s car from his private property?
IV. What is the name and address of the driver whom working for B & F Towing
Company removed the vehicle iiom John S. Shipley’s private property?
V. How many cars has B & F Towing Company removed hom individuals private fi
property without notice?.
VI. Before John S. Shipley’s vehicle was removed, there was a note placed in the
driver’s side window. What did the note read? y
_ VII. Who authorized the removal of John S. Shipley’s vehicle from his private
property?
VIII. What is the name of B & F Towing Company’s liability insurance carrier?
.,... . , I _!I$ ;;j
JOHN S. SHIPL h , pro se
Jomv s. srrrim v
609 Wildel Avenue
n Minquadale
New Castle, DE 19720
Plaintiff
Dated: 03.*04105 U

Case 1:04-cv-01530-JJF Document 6 Filed O3/07/2005 Page 3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIF Y that on this 4"‘ day of March, 2005, one copy of the
foregoing First fret of interrogatories and Production of Documents to the Defendant
was caused to be elivered to the following:
Smith, Katzenstein, Furlow, LLP
The Corporate Plaza
800 Delaware Avenue, 7* Floor
P.O. Box 410 I
Wilmington, Delaware 19899
JOHN S. SHIPLEY, pro se
JOHN S. SHIPLEY
609 Wildel Avenue
Minquadale ·
n New Castle, DE 19720
Plaintiff
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