Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :04-cv-01457-KAJ Document 24 Filed 07/07/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOHN R. BAKER, JR., *
*
Plaintiff, *
*
v. *
* C.A. N0. 04-1457 (KAJ)
TOWN OF SMYRNA; DAVID S. HUGG, *
HI, individually and in his official capacity *
as Town Manager; JOSEPH HEEGER, *
individually and in his official capacity as *
Supervisor of Public Works; and *
HARVEY LEGGETT, individually and in * TRIAL BY JURY DEMANDED
his official capacity as Supervisor of Streets, *
=l=
Defendants. *
PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26|a| (1;
Plaintiff John R. Baker, Jr., by and through his attorneys, 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 infomation that Plaintiff
may use to support his claims (but not solely for impeachment):
1. Plaintiff;
2. Defendant David S. Hugg, III, Smyrna Town Manager;
3. Defendant Joseph Heeger, Supervisor of Smyrna Public Works;
4. Defendant Harvey Leggett, Supervisor of Smyma Streets;
5. James Brown, employee of Town of Smyrna;
6. Theopoles Banes, employee of Town of Smyrna;
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

Case 1:04-cv-01457-KAJ Document 24 Filed 07/07/2005 Page 2 of 2
Response to Defendants' 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
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).
SCHNIITTINGER & RODRIGUEZ, P.A.
I
WILLIAM D. FLETCHER, JR.
Bar ID # 6
BY; é ~*' —;··‘·‘
NOEL E. PRIMOS
Bar ID #3124
414 S. State Street
P.O. Box 497
Dover, DE 19903
(302)6'/4-0140
Attorneys for Plaintiff
Dated: .7
VVDF/NEP:tcl