Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :05-cv—00055-KAJ Document 15 Filed 04/05/2005 Page 1 of 2
IN THE UNITE-D STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RO.B.l.l\§ I). N.lCIeIO.I,S, °"
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Plaintiff, "‘
v. * C. A. No. 05~0055-I<.AI
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BENNETT SECURITY CORPORATION *
A Delaware Corporation, and *
ALLEN FAMILY FOODS, INC. *
A Delaware Corporation, *
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Defendants. *
DEFE-NDANT ALLEN FAMILY FOODS, INC'S INITIAL `DISCLOSURES
PURSUANT TO FRCP 26ga;
Defendant Allen Farnily Foods, Inc. ("Alien’s") submits the following initial
disclosures pursuant to the Scheduling Order dated March 28, 2005 and Fed. R. Civ. P.
26(La):
A. Identities of individuals likely to have knowledge of discoverable infonnaticn that
may be used to Allerfs claims or defenses:
I. R. Greg Miller
Manager, Human Resources
Allen Family Foods
18752 Harbeson Road
Route 5
Harbeson, DE 19951
Mr. Milier will testify that he played no role in the terrniriatioii of
Plaintiffs ernployment by Defendant Bennett Security Corporation and
that he did not slander Plaintiff.
2. Any witness identitied through discovery or listed by Plaintiff.
B. Documents and things in the possession of counsel or the party that may be used
to support Al`len’s claims or defenses:

Case 1 :05-cv—00055-KAJ Document 15 Filed 04/05/2005 Page 2 of 2
1. A1len°s is aware of no such documents at this time.
C. identities of experts and their opinions:
Alien’s has not retained an expert at this time.
D. insurance agreements that would apply in the event of a judgment:
None.
E. Statement of the esis for any damages claimed:
A§len”s has made no claim for damages at this time.
5 if
. · i 5
Matthew F. Boyer (Dei. [Bar No. 2 @41)
CONNOLLY BOVE LODGE & HUTZ, LLP
The Nemours Building
1007 N. Orange Street
Wilmington, DE E9899
(302) 884-6585
Arthur M. Brewer (admitted pro /2410 vice)
SHAWE & ROSENTHAL, LLP
20 S. Charles Street, 1 lm Floor
Baltimore, MD 2120}
(410) 752-1040
Cozmseifor Defendcmt A/fen Fczrnitly Foods, It-tc.
DATED: April 5, 2.005
33972 2__§
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