Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :07-cv-00160-LPS Document 36 Filed O1/07/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SHEILA LAND, Individually and as Guardian :
of RAB, a minor, and Charles J. Durante, Esq. :
Executor of the Estate of Charles Andre Banks :
Plaintiffs, C.A. No.: 07-160-LPS
v. JURY TRIAL OF SIX DEMANDED
THE CITY OF DOVER and [JOHN DOES 1-5] U
PFC ROBERT BARRETT, CPL CARL
HUMPHREY, PFC JEFFREY GOTT, PFC KEVIN
STREADWICK,PFC BIAN CA RANGER,
in their Individual and Official capacities :
Defendants.
PLAINTIFFS’ RULE 26 DISCLOSURES
Plaintiff s hereby provides the initial disclosures required by Fed. R. Civ. P. 26(a)(l).
These disclosures are based on information reasonably available to Plaintiffs as of the date these
disclosures are served. Plaintiffs reserve the right to supplement these disclosures pending
additional investigation and discovery and as permitted by Fed. R. Civ. P. 26(e).
A. The name and, if known, the address and telephone number of each individual
likely to have discoverable information that the disclosing party may use to support its claims or
defenses, unless solely for impeachment, identifying the subjects of the information:
RESPONSE: At this time in addition to the named parties the following individuals are
likely to have discoverable infomation:
Richard T. Calleiy, M.D. Chief medical Examiner :
Judith G. Tobin Assistant State Medical Examiner

Case 1:O7—cv-00160-LPS Document 36 Filed O1/07/2008 Page 2 of 3
Delaware Heath and Social Services
200 S. Adam Street
Wilmington De 19801
Freddie O. Lawson: 1070 Facty Ave., Mattitude NY 11952
Bayhealth Medical Center
Kent General Hospital Center
640 South State Street, Dover DE 19901
Michele Septer
Patricia Hudson
Colleen Wessell
Laurie Dafonte
Randy Mitchell
Jo Ann Davis
Linda Bolduc
Dennis Thompson
Cathie Barron
Ruthann Coulson
Dr. Julie Slick
Any and all medical personnel who treated Mr. Banks at Bayhealth Medical Center
The following may be reached through the above employer.
B. A copy of, or a description by category and location of, all documents, data
compilations and tangible things in the possession, custody or control of the party and that the
disclosing party may use to support the disclosing party’s claims or defenses, unless solely for
impeachment:
RESPONSE:
Medical Records of Charles Banks: under the control and custody of undersigned counsel
Autopsy Report:
Delaware Heath and Social Services
200 S. Adam Street
Wilmington De 19801
Statements from employees at Bayhealth Medical Center
Bayhealth Medical Center
Kent General Hospital Center
640 South State Street, Dover DE 19901

Case 1:O7—cv-00160-LPS Document 36 Filed O1/07/2008 Page 3 of 3
Police Report or any investigations prepared by the Dover Police Department
C. A computation of any category of damages claimed by the disclosing party,
making available for inspection and copying, as under Rule 34 the documents or other
evidentiary material not privileged or protected from disclosure, on which such computation is
based, including materials bearing on the nature and extent of injuries suffered.
RESPONSE:
To be provided.
D. For inspection and copying, as under Rule 34, any insurance agreement under
which any person carrying on an insurance business may be liable to satisfy part of all of a
judgment which may be entered in the action or to indemnify or reimburse for payments made to
satisfy the judgment.
RESPONSE:
At this Plaintiffs are unaware of any insurance agreements that may be applicable
to this action.
RICHARD R. WIER, JR., P.A.
/s/ Michele D. Allen
Richard R. Wier, Jr. (#716)
Michele D. Allen (#4359)
Two Mill Road - Suite 200
Wilmington, DE 19806
(302)888-3222