Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv—OOO43-IVIPT Document 15 Filed O1/30/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BEST UNIFORMS, INC. :
Plaintiff, C.A. N0.: 07-43 MPT
v. AFPIDAVIT OF DEFENSE
: REQUIRED
CHRISTINA CONSOLIDATED
SCHOOL DISTRICT, CHRISTINA :
SCHOOL BOARD :
Defendants. :
PLAINTIFFS’ RULE 26 DISCLOSURES
Plaintiff hereby provides the initial disclosures required by Fed. R. Civ. P. 26(a)(l).
These disclosures are based on information reasonably available to Plaintiff as of the date these
disclosures are served. Plaintiff reserves 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 information:
Randy Smale, Sales Manager Best Uniforms
Len Szkotak, President/Owner of Best Uniforms
Robert LaBuz. Financial Controller
Above can be reached by undersigned counsel
Ronald G. Albence

Case 1:07-cv—OOO43-IVIPT Document 15 Filed O1/30/2008 Page 2 of 3
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:
Copy of the signed contract between Best Uniforms and Christina School District.
Correspondence from Best Uniforms to Ron Albence
Best Uniform Requirements and Pricing for Christina School District
Best Uniform Confidential Rental Quote for Christina School District
State of Delaware Purchase order from Christina School District to Best Uniforms
Best Uniforms Invoice dated November 15, 2006 for Christina School District
E—mails from Ron Albence to Best Uniforms
Invoices from Best Uniforms related to Christina School District
The above documents are under the custody and control of undersigned counsel.
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.

Case 1:07-cv—OOO43-IVIPT Document 15 Filed O1/30/2008 Page 3 of 3
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 Plaintiff is 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
Dated: January 30, 2008