Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :05-cv-00055-KAJ Document 17 Filed 07/07/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBIN D. NICHOLS, ;
Plaintiff, *
* C.A. No. 05-555 (KAJ)
v. ;
BENNETT DETECTIVE & PROTECTIVE, * TRIAL BY JURY DEMANDED
AGENCY, INC., a Delaware corporation, *
and ALLEN'S FAMILY FOODS, INC., *
a Delaware corporation, :
Defendants. *
PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26§a)§ 1;
Plaintiff Robin D. Nichols by and through her attorneys, Schmittinger and Rodriguez, P.A.,
hereby discloses the information required by Ped. R. Civ. P. 26(a)(1) to Defendant as follows:
A. The following individuals are likely to have discoverable information that Plaintiff
may use to support his claims (but not solely for impeachment):
1. Plaintiff;
2. Joseph "Josh" Whiteman;
3. Greg Miller;
4. Wayne Kellam.
B. Attached are copies of all documents, data compilations, and tangible things in the
possession, custody, or control of Plaintiff that Plaintiff may use to support her claims (but not
solely for impeachment), other than infomation related to Plaintiffs damages.
C. The categories of damages claimed by Plaintiff are as set forth in Plaintiffs
Complaint. These damages are not subject to quantification at this point. Evidence regarding
damages will be provided in discovery as requested by Defendant.

Case 1:05-cv-00055-KAJ Document 17 Filed 07/07/2005 Page 2 of 2
D. Plaintiff has no obligation for disclosure pursuant to Fed. R. Civ. P. 16 (a) (1) (D).
SCHMITTIN GER & RODRIGUEZ, P.A.
WHJLIAM D. FLETCHER, JR. ,.7 ‘ ‘
Bar #362 ff Hf f’
BY; ’ Q J ‘····‘"‘
NOE E. PRIMOS
Bar ID #3124
414 S. State Street
P.O. Box 497
Dover, DE 19903
Attorneys for Plaintiff
Dated: “71`110€’D
WDF/NEP/tcl