Free Amended Document - District Court of Delaware - Delaware

Case 1:04-cv-01528-KAJ

Document 43

Filed 07/27/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JACLYN DRYDEN, Plaintiff, } } } } } } } } } } } }

C.A. No. 04-1528-KAJ

v.

DOLLAR GENERAL CORPORATION, and DOLGENCORP, INC. Defendants.

AMENDED RULE 26(a)(1) DISCLOSURE REQUIREMENTS BY THE PLAINTIFF A. Identities of individuals likely to have discoverable information that the disclosing party may use to support its claims or defenses. Jaclyn Dryden Eric Dryden James Sluter Robert Hartly Bill Berry Debra Griffin (Plaintiff's mother) Sarah Griffin (Plaintiff's Stepsister) Helen Whitely (Plaintiff's Grandmother) Mrs. Kennedy, District Manager of Dollar General Store at time of claim Employees at the Dollar General Store located at 908 S. Dupont Hwy in Dover Delaware, who worked there in the Fall 2002 Employees of the Department of Labor and EEOC who investigated the claim

Medical Staff and Administrative Staff at St. Jones Hospital, which includes Dr. Yvonne Roque and Dr. Sibley Vocational Rehabilitation Office at Dover, DE during Spring 2004.

Lynn Beuleh (Mr. Dryden's Boss)

Case 1:04-cv-01528-KAJ

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B. A copy of or a description by category and location of all documents, data compilations, and tangible things that are in the possession, custody, or control of the party and that the disclosing party may use to supports its claims or defenses, unless solely for impeachment;

1. Documentation from the Department of Labor and EEOC. (Including entire EEOC file) 2. Letter to Trina Wheedleton from Robert Hartley 3. Letter to Trina Wheedleton from James Sluter 4. Conciliation Questionnaire. 5. Medical Records for Jaclyn Dryden 6. Medical Bills for Jaclyn Dryden 7. Witness Statement by Jaclyn Dryden 8. Earnings Statements from Ollie's and NCO Financial Systems 9. Jaclyn Dryden Work History & Office Notes (protected by attorney client privilege and work product) 10. Letter by Eric Dryden to Trina Wheedleton 11. Social Security Disability Award dated September 24, 2004 C. Identities of experts and their opinions if known at this time. Dr. David Sibley Kent/Sussex Community Mental Health Center Dover Mental Health Clinic 805 River Road Dover, DE 19901 Dr. Sibley opines that Ms. Dryden suffers from Posttraumatic Stress Disorder and Panic Disorder, and that these conditions were mostly likely caused by her reported sexual harassment experiences while working at Dollar General.

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Case 1:04-cv-01528-KAJ

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See also the June 14, 2005 letter/report by Dr. Sibley for further information about his opinion. D. Insurance agreements in force. None. E. Statement of the bases for any damages claimed: Plaintiff was subject to sexual harassment in the work place by an employee of the Defendants. Despite her complaints to management nothing was done and management retaliated against her by questioning her attendance. Ms. Dryden has suffered significant mental, emotional and psychological pain and distress due to the continual and persistent harassment and discrimination. She has been diagnosed as having Posttraumatic Stress Disorder and Panic Disorder. She has suffered and continues to suffer physical illness and injury, which includes chest pain, nausea, vomiting, anxiety, panic attacks, agoraphobia and extreme fear of men. She lost her job and income because of the Defendant's actions. She has attempted to return to work on several occasions, because of her fear of men and panic attacks with chest pain, she has been unable to maintain employment.

GRADY & HAMPTON, LLC

Dated: July 27, 2005

Laura F. Browning, Esq. (4504 John S. Grady, (009) Laura F. Browning, (4504) 6 North Bradford Street Dover, DE 19904 [email protected] [email protected] (302) 678-1265 Attorneys for Plaintiff Dryden

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