Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:04-cv-01393-KAJ Document 18 Filed 03/31/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PAUL HARVEY, *

Plaintiff, *
* C. A. No. 04-1393 (KAJ)
v. *
* TRIAL BY JURY DEMANDED
DOLLAR TREE STORES, INC., *
a Virginia corporation, I
Defendant. *
PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26{a)(1)
Plaintiff Paul Harvey, by and through his attorneys,
Schmittinger and Rodriguez, P.A., hereby discloses the information
required by Fed. R. Civ. P. 26(a)(l) 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):
l. Plaintiff;
2. Mary Poole, Store #53 Manager for Defendant
corporation;
3. Barbara Boley, Assistant Store #53 Manager for
Defendant corporation;
4. David Crawford, District Manager for Defendant
corporation;
B. See Plaintiff's Response to Defendant's Request for
Production for copies of all documents, data compilations, and

Case1:04-cv-01393-KAJ D0cument18 Filed 03/31/2005 Page20f2
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
Plaintiff's damages.
C. The categories of damages claimed by Plaintiff are as
set forth in Plaintiff‘s 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. l6(a)(l)(D).
SCI-IMITTI GER & RODRIGUEZ, P.A.
j L j f 1 ? _,
BY://l "i ` j~
l iam D. Fl cher, Jr;
_ Bar ID #362 j
4l4 S. State Street ¢»“
P.O. Box 497
Dover, DE 19903
(302)674—0l40
Attorneys for Plaintiff -
Dated:
WDF:tCl