Free Motion to Compel - District Court of Delaware - Delaware

H ,_ Case 1 :04-cv-00419-JJF Document 107 Filed 09/14/2007 Page 1 of 3
‘ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Cathy D. Brooks-McCollum CIVIL ACTION NO: 04-419 (JJF)
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRIAL REQUESTED
As a Director
PO BOX ,. . .·. -· V · -7 ·- · -. -·— ·v·: ·~~r:·r.*r::-r ..,..,.;1<1'!'
(302) 521-124 1 _ f .
(1>LAu~tT1;FF) _ j,
vs_ g SEP 11 211111
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State Farm Insurance Company " _$_ [`)|STF{$(}1g" GOURT _ g
CDEFENDANTSJ `
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CURRENT DISCOVERY DELAYS RELATED TO THIS CASE
Plaintiff submitted the attached Interrogatories upon various individuals, as well a request for Production of
Documents several times. Therefore, Plaintiff is asking the court should these items not be complied with per the Courts
Order by October 9, 2007 to issue an Order instructing each party which Interrogatories they must comply with, and the
documents they must turn over to Plaintiff. ,
Plaintiff has issued the attached Subpoena, as well as the one to Wachovia Bank to turn over Corporate
documentation, which are not afforded Attorney Client Privilege, in that Plaintiff is and has been determined to have been a
valid Stockholder and Director, in addition to the parties never claimed they did not commit crimes in obtaining the
documents, but merely have argued immunity, this takes away any privilege obtained between Attorney Kafader, Gouge and
the other parties who participated along with Defendants in these pleadings.
Plaintiff previously submitted other discoverable items to the court regarding admissions and Request Of Production
of Documents, Depositions, etc. of which Plaintiff requests the court to issue an Order on should they too not be fully
complied with.
Qt; rg i if hn
_ Cathy . Brooks- cCollum
PO Box 12166
Wilmington, DE 19850
August 15, 2007

Case 1 :04-cv-00419-JJF Document 107 Filed 09/14/2007 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Cathy D. Brooks-McCollum CIVIL ACTION N0: 04-419 (JJF)
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRIAL REQ QUESTED
PO Box 12166
Wilmington, DE 19850
As a Director
(PLAIN TIFF)
vs.
State Farm Insurance Company
(DEFENDAN TS)
PROOF OF SERVICE
I Cathy D. Brooks—McCol1um hereby certify that on the 13"1 day of September 2007, I will and have caused to be served a
true and correct copy of the foregoing two Motion electronically upon defendants:
Casarino, Christman & Shalk
Stephen P. Casariuo
800 North King St, Suite 200
P.O. Box 1276
Wilmington, DE 19899
(302) 594-4500
(302) 594-4509 Fax .
ff) A rj
tk L `”t v - J 1
/§/ Cathy . Brooks—McCo11u1n(Pro Se)
PO Box 12166
Wilmington, DE 19850
(302) 521-1241

Case 1 :04-cv-00419-JJF Document 107 Filed 09/14/2007 Page 3 of 3 n -
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Case 1:04-cv-00419-JJF

Document 107

Filed 09/14/2007

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Case 1:04-cv-00419-JJF

Document 107

Filed 09/14/2007

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Case 1:04-cv-00419-JJF

Document 107

Filed 09/14/2007

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