Free Disclosure Statement - District Court of Delaware - Delaware

Case 1 :08-cv-00165-SLR Document 22 Filed 08/1 1/2008 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA,
On behalf and for the benefit of,
LGS GROUP, LLC
t/a LGS GROUP — BALTIMORE FRAMING and
LGS GROUP — S. CHARLOTTE FRAMING,
Plaintiff, Case No. 08-165-UNA
v.
SAFECO INSURANCE COMPANY,
DUYSSEY INTERNATIONAL, INC.,
Defendants.
DEFENDANT’S RULE 26ga[g1[ INITIAL DISCLOSURES
Comes now the Defendant Odyssey International, Inc. (hereinafter “Odyssey"), pursuant to
Federal Rule of Civil Procedure 26(a)(1) and submits these initial disclosures.
I. PERSONS WITH KNOWLEDGE.
Mike Tingey; Odyssey International, Inc. Contract, work progress, amounts paid on the
contact, invoices, claims being made by subcontractors of LGS Group, LLC. (801) 532-7080.
Strong 8; Hanni, 3 Triad Center, Suite 500, Salt Lake City, Utah 84180.
Steve Young, Odyssey International, Inc., Project management, contract, work progress.
(801) 532-7080. Strong 8CHanni, 3 Triad Center, Suite 500, Salt Lake City, Utah 84180.
Mike Austin, Odyssey International, Inc. ]ob site related issues and project management.
(801) 532-7080. Strong 8CHanni, 3 Triad Center, Suite 500, Salt Lake City, Utah 84180.
]ames Lawson, LGS Group, LLC. Contract, work progress, and amount owed on the
contract. (401) 333-9995. 80 Fisher Road, Unit 49, Cumberland, Rhode Island 02864.
Carrie Lawson, LGS Group, LLC. Submittal issues, billing, issues, and payments received by
LGS. (401) 333-0005. 80 Fisher Road, Unit 49, Cumberland, Rhode Island 02864.

Case 1:08-cv-00165-SLR Document 22 Filed 08/11/2008 Page 2 of 4
Mark Miller, LGS Group-S. Charlotte Framing, LLC. Project management, subcontract,
payroll, and manpower. (410) 256-8687. 9521 A. Hom Ave., Nottingham, Maryland 21236.
Greg Pezza, formerly with LGS Group. Estimating, subcontract and billing issues. Las
known contact information: (401) 333-9995. 80 Fisher Road, Unit 49, Cumberland Rhode Island
02864.
]eff Walsh, fonnerly with LGS Group. Estimating, subcontract and billing issues. Las
known contact information: (401) 333-9995. 80 Fisher Road, Unit 49, Cumberland Rhode Island
02864.
Employees of LGS Group, LLC/ S. Charlotte Framing, LLC yet to be identified. (410) 256-
8687. 9521 A. Hom Ave., Nottingham, Maryland 21236.
Employees and representatives of subcontractors of LGS Group, LLC specifically yet to be
identified. Scope of the work, payments on subcontract agreements with LGS Group, LLC.
Unknown telephone numbers. Unknown addresses.
II. DOCUMENTS RELEVANT TO THE DISPUTED FACTS. V
The following is a description by category, of non-privileged documents and tangible things
that Defendant may use to support its claims, unless solely to impeach. 'Ihese documents are
located at Odyssey Intemational, Inc., 135 North Duke, Lancaster, Pennsylvania 17602 and will be
made available to Plaintiff pursuant to Plaintiff’s Request for Production of Documents.
(a) Subcontract Agreement between Odyssey and LGS Group, LLC.
(b) Branch Agreement between LGS Group and LGS Group Charlotte. i
(c) Contact documents.
(d) Submittals
(e) Payment requests.
(f) Change orders. U
(g) Correspondence.
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Case 1:08-cv-00165-SLR Document 22 Filed 08/11/2008 Page 3 of 4
(h) Invoices.
(i) Copies of checks.
III. COMPUTATION OF DAMAGES.
Defendant has not alleged claims against Plaintiff, however, if Defendant prevails in this
litigation, Defendant will seek reimbursement of attorney fees as provided in the Subcontractor
Agreement.
IV. INSURANCE AGREEMENTS.
Defendant does not have any knowledge of any insurance agreement under which any
person carrying on a business may be liable to satisfy part or all of the a judgment which may be
entered into the action or to indemnify or reimburse for payments made to satisfy the judgment,
other than the payment bond attached to the Complaint.
V. AMENDMENT OF DISCLOSURE STATEMENT.
The foregoing initial disclosures are based upon the information reasonably available to
Defendant at this time. Defendant reserves the right to amend, modify or add to this disclosure
statement as discovery or circumstances may warrant.
Etzur Austin Rmaoorsi T/uttov 8c Monottt, PA
J 41 /
] s1¤.K11>1>, =a r I #190]
Dated: August 11, 2008 2 0 Wrangle Hill Road ` e 210
Bear, DE 19701 / /
302-327-1100
I Attorneys for Defendants
Q[CiO747’B€L'
H. Burt Ringwood, Esquire [# 5787]
Snzorsic AND Hiusust
3 Triad Center, Suite 500
Salt Lake City, Utah 84180
3

Case 1:08-cv-00165-SLR Document 22 Filed 08/11/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on August 11, 2008 a copy of Defendant’s Rule 26(a) (1) Initial
Disclosures was served via electronic filing upon counsel as follows:
William W. Erhart, Esquire
William W. Erhart, P.A.
800 North King Street, Suite 303
Wdmiiigton, DE 19801
] F. Kipp, [# 1%] é
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