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

Case 1:07-cv-00244-JJF

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Filed 04/03/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HENRY R. TAYLOR, JR., Plaintiff, v. KATHLEEN D. FELDMAN, et al., Defendants. : : : : : : : : :

C.A.No. 07-244-JJF

FELDMAN'S 1st REQUEST FOR PRODUCTION DIRECTED TO PLAINTIFF Defendant Kathleen D. Feldman hereby requests that Plaintiff produce at Defendant's attorneys' office for the purpose of inspection and copying, all of the following documents or evidence within 30 days pursuant to Fed.R.Civ.P. 34. These requests for production are continuing and the items requested must be kept current by supplementation. As used in this request for production, "you" or "yours" means and refers to plaintiff, her attorney(s) and their agents and employees. Defendant request Plaintiff produce complete originals of the following: 1. Any and all documents and tangible things referred to in plaintiff's

complaints in this matter. 2. Any and all documents and tangible things identified or that should

be identified in response to defendant's interrogatories.

Case 1:07-cv-00244-JJF

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Filed 04/03/2008

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3.

Any and all reports, including drafts, by an expert retained by

plaintiff in connection with this matter as well as his or her current qualifications, and any documents supplied or reviewed by that individual. 4. Any and all statements, in writing or oral, by any party or witness, in

any form, relating to the incidents that form the basis of this lawsuit. 5. Any and all videotapes, audiotapes, or photographs taken by you that

refers or relates to any claim or defense in the present matter. 6. Any and all documents or physical evidence that supports any claim

of Plaintiff for damages of any nature. 7. Any and all court decisions that involve a claim similar as set forth

in the complaint in this matter. STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Marc P. Niedzielski Marc P. Niedzielski (#2616) Deputy Attorneys General 820 North French Street 6th Floor Wilmington, DE 19801 (302) 577-8324

DATED: April 3, 2008 -2-

Case 1:07-cv-00244-JJF

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Filed 04/03/2008

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CERTIFICATE OF SERVICE I certify that on the date indicated below I served two copies of the attached document by regular U.S. Mail on the following: Henry R. Taylor, Jr. SBI 00159464 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977

/s/ Marc P. Niedzielski Marc P. Niedzielski (2616) Deputy Attorney General Department of Justice 820 North French Street Carvel Building, 6th Floor Wilmington, DE 19801

DATED: April 3, 2008 -3-