Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :05-cv-00046-JJF Document 12 Filed 05/O3/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WILLIAM HANSON, III, *
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Plaintiff, *
* C.A. N0. 05-0046 (JJF)
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v. *
LOWE'S HOME CENTERS, INC., et al, * TRIAL BY JURY DEMANDED
*
Defendants. *
PLAINTIF F 'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26§alg1[
Plaintiff William Hanson, HI, by and through his attomeys, Schmittinger and Rodriguez,
P.A., hereby discloses the information required by Fed. 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 William Hanson, III;
2. Yvette Schriver, Store Manager, Lowe‘s #587;
3. Linda Myers, Assistant Store Manager, Lowe‘s #587;
4. Jeremy Leaman, Ideal Merchandising;
5. Keith Dominick, Assistant Store Manager, Lowe‘s #587;
6. Carlos Vazquez, Zone Manager, Lowe's;
7. Jeff Ramiez, Department Manager, Lowe's;
8. Steve Folder, Plumbing Specialist, Lowe's;
9. Corlene (last name unknown), Manager, Lowe's;
10. Buck (last name unknown), Electrical Specialist, Lowe's.
B. Copies of all documents, data compilations, and tangible things in the possession,
custody, or control of Plaintiff that Plaintiff may use to support his claims (but not solely for
impeachment), other than information related to Plaintiffs damages are attached to Plaintiffs
Response to Defendant DDP Holdings' First Request for Production of Documents.
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

Case 1:05-cv-00046-JJF Document 12 Filed 05/O3/2005 Page 2 of 2
damages will be provided in discovery as requested by Defendant.
D. Plaintiff has no obligation for disclosure pursuant to Fed. R. Civ. P. 16(a)(1)(D).
SCHMITT§ER & RODRIG Z, P .
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Q/W` i D. Fletcher Jr. ··
Bar ' 362
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Noel . Primos
Bar ID #3124
414 S. State Street
P.O. Box 497
Dover, DE 19903
Attomeys for Plaintiff
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Dated: ? 2* “O }
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