Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1:08—cv—00379-Gl\/IS Document 7 Filed 08/21/2008 Paget of3
IN THE UNITED STATE DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RICHARD NOWAK and LUCINDA L. : C.A. NO.: 1:08-cv—379
WTLLIAMS :
riaimtrrs, i
v.
DAVID M. BORTLE, JR and AUDREY JURY OF 12 DEMANDED
ROSENBALM :
Defendants.
REQUEST FOR PRODUCTION DIRECTED
TO PLAINTIFF RICHARD NOWAK
Defendants request the plaintiff to produce for examination and copying at the
office of the attorney for the defendant on or before thirty (30) clays from the date of
receipt of this request, the following items:
l. All hospital records, doctors' summaries and reports, reports concerning any
physical tests performed on or concerning the injured plaintiff and any other matter in
writing prepared by or on behalf of any person trained in the healing arts concerning the
iniured plaintiffs past, present, or future physical condition insofar as such matters in
writing may be in the possession, custody or control of the plaintiff or available to the
plaintiff, plaintiffs insurer, or plaintiffs attorney upon request by him to any doctor,
hospital or other person.
RESPONSE:
2. Copies of all statements, bills or canceled checks showing the amount charged
for services rendered to the injured plaintiff or items sold to the plaintiff in connection
with the care of the injured plaintiffs alleged injuries,

Case 1:08—cv—00379-Gl\/IS Document 7 Filed 08/21/2008 Page 2 of 3
RESPONSE:
3. Copies of all photographs, sketches, diagrams or other drawings taken by, or
prepared by you, or on your behalf, or in your possession, or available to you, conceming
any aspect ofthe litigation.
RESPONSE:
4. Copies of Federal income Tax Returns of the plaintiff for the years 2003
through 2007.
RESPONSE:
5. Copies of all statements or summaries of interviews taken of any person with
respect to any issue in the case, including, but not iiniiteci to the plaintiff or his agents and
the defendant or the defendants agents.
RESPONSE:
6. Copies of ali reports of investigation, findings of fact, observation of facts or
circumstances or any other matter relating to any aspect ofthe litigation.
RESPONSE:

Case 1:08—cv—00379-Gl\/IS Document 7 Filed 08/21/2008 Page 3 of 3
7, Any reports by any person qualifying as an expert containing opinions and/or
facts on which opinions are based concerning any aspect ofthe litigation.
RESPONSE:
8. Insofar as any insurer, including, but not iiinited to worlonen's compensation
insurers or automobile PIP coverage insurers, may have reports, records or the like,
which are available to the plaintiff upon request, then copies of such reports and records.
RESPONSE:
9,. Any other relevant documents available to you and relied upon or mentioned
in your responses to discovery,.
RESPONSE:
BIFPBRATO GENTILOTTI LLC
/s/ Maria J. Poehner
MAR1A J , POEHNER, Esquire (32} 3)
800 N, King Street
P.O, Box 2165
Wil1ningt0n,DE i9899—2i65
(302) 429-1900
Attorney for Defendants
Date: August 21, 2008

Case 1 :08-cv-00379—Gl\/IS Document 7-2 Filed 08/21 /2008 Page 1 of 1
IN THE UNITED STATE DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RICHARD NOWAK and LUCINDA L. : C.A. NO.: 1:08-cv—379
WILLIAMS :
Pimstts, 2
v.
DAVID M. BORTLE, JR and AUDREY JURY OF 12 DEMANDED
ROSENBALM :
Defendants.
NOTICE OF SERVICE
PLEASE TAKE NOTICE that on this 21st day of August, 2008, the undersigned has
caused to be served a true and correct copy oflnterrogatories mid Request for Production
Directed to Plaintiff Richard Nowak to be delivered via Electronic Filing on the following:
Cynthia H. Pruitt, Esquire
Doroshow, Pasquale, Krawitz & Bhaya
1202 Kirkwood Highway
Wilmington, DE 19805-2i20
BIFFERATO GENTILOTTE LLC
/s/ Maria J. Poehner
Maria J. Poelmer, Esquire (Del. LD. #3213)
800 N. King Street, First Floor
PO. Box 2165
Wilmington, DE 19899-2165
(.302) 429-1900
Attorney for Defendants

Case 1:08-cv-00379-GMS

Document 7

Filed 08/21/2008

Page 1 of 3

Case 1:08-cv-00379-GMS

Document 7

Filed 08/21/2008

Page 2 of 3

Case 1:08-cv-00379-GMS

Document 7

Filed 08/21/2008

Page 3 of 3

Case 1:08-cv-00379-GMS

Document 7-2

Filed 08/21/2008

Page 1 of 1