Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1:04-cv—01324-JJF-LPS Document 116-3 Filed 10/26/2005 Page 1 013
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Case 1:04-cv—01324-JJF-LPS Document 116-3 Filed 10/26/2005 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
THOMAS A. EAMES, ROBERTA L. EAMES )
and TAMIVIY EAMES, on behalf of )
themselves and all others )
similarly situated, )
)
· Plaintiffs, ) C.A. No. O4-CV-1324KAJ
J . v- )
NATIONWIDE MUTUAL INSURANCE )
COMPANY, )
)
Defendant. )
EAMES PLAINTIFFS' FIRST SET OF
REQUESTS FOR PRODUCTION OF DOCUMENTS
Pursuant to Federal Rule of Civil Procedure 34, plaintiffs Thomas A. Eames, Roberta L.
Eames and Tammy Eames (collectively, the "Eames plaintiffs") request that defendant
Nationwide Mutual Insurance Company produce for examination and copying at the office of the
Eames plaintiffs' attorneys, and in the time prescribed by that Rule, the following items:
Definitions
I. References to "you", "your" or "Nationwide" are to the defendant Nationwide Mutual
Insurance Company.
2. The term "PIP" refers to Persona] Injury Protection or other first party "no fault"
insurance benefits for medical expenses, lost earnings or funeral expenses provided or to be
provided under policies of automobile insurance.
3. The term "document" shall have the broadest meaning permissible under the Federal
Rules of Civil Procedure, and shall include (without limitation) documents created or stored by
electronic means.
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Case 1:04-cv—01324-JJF-LPS Document 116-3 Filed 10/26/2005 Page 3 of 3
Documents to be Produced
1. A11 documents that refer to or characterize limits of liability for PIP coverage as "fu1l."
2. All documents that refer or relate to the characterization of limits of liability for PIP
coverage as "full."
3. All documents or other recorded material that refer or relate to the training, instruction
or education of Nationwide's employees or agents (including without limitation insurance agents)
with respect to the characterization of PIP limits as "full."
Respectfully submitted,
MURPHY SPADARO & LANDON
(\ 2,;.., Q_ Sk, sz; as
John S. Spadaro, No. 155
1011 Centre Road, Suite 210
Wilmington, DE 19805
(302) 472-8100
Attorneys for plaintiffs Thomas A. Eames,
Roberta L. Eames and Tammy Eames (on
behalf of themselves and all others similarly
situated)
April 7, 2005
1 l922E