Free Remark - District Court of Delaware - Delaware

_ _ E Case 1 :04-cv-00419-JJF Document 109 Filed 10/04/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
1
FOR THE DISTRICT OF DELAWARE 1
Cathy D. Brooks-McCollum CIVIL ACTION NO: 04-419 (JJF)
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRLAL REQUESTED
As a Director
PO Box 12166 O ~
Wilmington, DE 19850
(302) 521-1241 .. . _ ( _o_,_ n;, __, I
[email protected] ( F Q L E g l
~-· ` " `· ` ` . V ih "" " " `§ ,-
vs_ ;. 0CT »~· 4 ZGBF l
State Farm Insurance Company ‘---
(DEFENDANTS) . ,il.. . l 1.1,. . .
PLAlNT[FF’S DISCOVERY ISSUES DUE T0 COURT Q D SCQ n i
l
1. Plaintiff requested that Defendants supply them with all copies of the Emerald Ridge Insurance
I
Company. These documents go directly toward the support of Defendants Tortfeasor actions.
2. Plaintiff requested that certain members of the State Farm Staff be deposed, of which has not `
been complied with.
3. Plaintiff requested that Defendants supply them with a copy of the Deposition taken at their
request, accessing those costs against the Corporations policy, of which Plaintiff Cathy Brooks-McCollum
directly paid into until 2005, which does not matter when requiring that all Policies be supplied up until the period
of 2007. These defendants have failed to comply. .
4. Plaintiff requested that Defendants make certain Admissions (Supplied to The Courts), and if
there were any that they felt they could not answer to state the reason, why. Defendants failed to comply with all
Admissions outlined. Whereby Plaintiffs ask that the court indicate what Admissions Defendants must answer.
5. Plaintiff requested that other parties who were Joint Tortfeasors along with these defendants
answer certain Interrogatories (Supplied to The Court), which have not been complied with to date. Plaintiff
specifically asked that these items be answered, as not to allow those parties to at any point argue ineffective
counsel, for not being hilly formed. Plaintiff also asked that Defendants answer these Interrogatories, knowing

_ _ , Case 1 :04-cv-00419-JJF Document 109 Filed 10/O4/2007 Page 2 of 4
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Defendants prior practices of placing individuals and Corporations in a financial disarray, and not meeting the
terms of their Insurance policies, only to abandon those parties after they themselves contributed mostly to the
reckless actions. Plaintiff would ask the court to order that the Interrogatories be answered, and which ones, and
that each Defendant have them notarized personally, as not to allow any counsel to answer for them, especially
when some of the questions relate to ineffective counsel. =
6. Plaintiff requested from Defendants Depositions, Insurance Policies, and all documents relating
to Emerald Ridge Service Corporation, which are Corporate property, of which have not complied with,
wherefore Plaintiff ask that the court order through Subpoena that the documents be produced. These items are
available through the Insurance Policy payments. I
7. Plaintiff requested that the corporations banking records be produced for inspection in that it has
been determined that Plaintiff Cathy Brooks-McCollum was a stockholder, as well as a Director, and presented a
Subpoena as to have those items turned over. Plaintiff further asks that the court order that all items be produced.
Plaintiff respectfully, ask that the court allow plaintiff to address these issues in their Reply Brief on
Defendants being Joint Tortfeasors after their Opening Brief supporting Defendants Tortfeasor actions, and {
supply to the Court the discoverable items. Plaintiff has indicated in Exhibits AK through AQ items which will
be supplied to the Court, upon those items being presented to Plaintiff, as well as other items, which have to be re-
produced.
Respectfully submitted,
/s/ Cathy D. Brooks-McCollum
PO Box 121 66
Wimington, DE 19850 .
(302) 521-1241
October 2, 2007

Q , , Case 1 :04-cv-00419-JJF Document 109 Filed 10/O4/2007 Page 3 of 4 I
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1
1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE 1
1
Cathy D. Brooks-McCollum CIVIL ACTION NO: 04-419 (JJF) U
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRIAL REQUESTED 1
As a Director 1
PO Box 12166
Wilmington, DE 19850 ‘
(302) 521-1241 l
[email protected] 1
(PLAINTIFF)
1
vs. j
State Farm Insurance Company
(DEFENDAN TS)
PROOF OF SERVICE
I Cathy D. Brooks-McCollum hereby certify that on the Sth day of October 2007, I will and have
caused to be served a true and correct copy of the foregoing Brief electronically upon defendants: i
1
Casarino, Christman & Shalk i
Stephen P. Casarino
800 North King St, Suite 200
P.O. Box 1276
Wilmington, DE 19899
(302) 594-4500
(302) 594-4509 Fax
/s/ Cathy .Brooks—McCo11um (Pro Se)
PO Box 12166
Wilmington, DE 19850
(302) 521-1241

Case 1 :04-cv-00419-JJF Document 109 Filed 10/O4/2007 Page 4 of 4
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Case 1:04-cv-00419-JJF

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