Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00410-MPT

Document 54

Filed 02/20/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SININA TALLEY, Plaintiff, v. COMCAST CORPORATION, INC., EXPERIAN INFORMATION SOLUTIONS, INC., and EASTERN ACCOUNT SYSTEM OF CONNECTICUT INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 07-410 (MPT)

PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO RULE 26(a) Plaintiff, through her legal counsel, hereby disclose the information required by Rule 26(a) to Defendants as follows: 1. IDENTIFICATION OF INDIVIDUALS WITH SUPPORTIVE INFORMATION. a. All parties to this action and their representatives. b. Sinina Talley, 809 Arthur Springs Lane, New Castle, Delaware 19720. All aspects of this litigation. Subscription with Comcast; termination of subscription, return of equipment and payment of bills. Credit prior to Comcast report to Eastern. Communications with Comcast and Eastern and Experian regarding inaccurate report. Attempts to obtain credit after reports from Comcast and Eastern. Financial consequences of denied credit. Medical care sought and received. c. Dennis Shipman, 809 Arthur Springs Lane, New Castle, Delaware 19720. Injury which has occurred to Talley. d. Poonam Dulai, M.D., neurologist and psychologist treating Talley.

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e. Representative of Wilmington Savings Fund Society, 833 Market Street, Wilmington, Delaware 19801, loans to Talley. 2. IDENTIFICATION OF DOCUMENTS WITH SUPPORTIVE INFORMATION. a. See Plaintiff's documents attached hereto. b. Plaintiff incorporates by reference documents produced by Defendants. 3. COMPUTATION OF DAMAGES. a. Statutory damages b. Actual damages are accruing. They include medical treatment for Plaintiff, lost income from Plaintiff's business, foreclosure by WSFS, interest on credit card, attorney's fees. 4. IDENTIFICATION OF INSURANCE. a. Not applicable.

/s/ Douglas A. Shachtman
DOUGLAS A. SHACHTMAN, I.D. No. 756 Douglas A. Shachtman & Associates 1200 Pennsylvania Avenue, Suite 302 Wilmington, DE 19806 (302) 655-1800 Attorney for Plaintiff DATED: February 20, 2008

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CERTIFICATE OF SERVICE I hereby certify that on February 20, 2008, I electronically filed PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO RULE 26(a) with the Clerk of the Court using CM/ECF which will send notification of such filing to the following: Thomas C. Grimm, Esq. James W. Parrett, Jr. Morris Nichols, Arsht & Tunnell LLP 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 Chad M. Shandler, Esq. Richards, Layton & Finger, P.A. One Rodney Square P.O. Box 551 Wilmington, DE 19899 Boyd W. Gentry, Esq. Surdyk, Dowd & Turner Co., L.P.A. Kettering Tower, Suite 1610 40 North Main Street Dayton, OH 45423 C. Scott Reese, Esq. Eric M. Andersen, Esq. Cooch and Taylor, P.A. 824 N. Market Street, Suite 1680 Wilmington, DE 19899-1680

Lynn M. Marvin, Esq. Jones Day 222 East 41st Street New York, NY 10017

/s/ Douglas A. Shachtman
DOUGLAS A. SHACHTMAN, I.D. No. 756 Douglas A. Shachtman & Associates 1200 Pennsylvania Avenue, Suite 302 Wilmington, DE 19806 [email protected] (302) 655-1800 Attorney for Plaintiff DATED: February 20, 2008

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