Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00410-MPT

Document 53

Filed 02/19/2008

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FOR THE DISTRICT OF DELAWARE SININA TALLEY Plaintiff, v. COMCAST CORPORATION, INC., et al. Defendants : : : : : : : : : : CASE NO.: 1:07-cv-00410 JUDGE MARY PAT THYNGE

DEFENDANT EASTERN ACCOUNT SYSTEM OF CONNECTICUT, INC.'S INITIAL DISCLOSURES Now comes Defendant Eastern Account System of Connecticut, Inc. ("Defendant"), by counsel, and for its Initial Disclosures, provides as follows: 1. Individuals likely to have discoverable information which Defendant may use to support its claims or defenses: A. B. All parties to this action and their representatives Steve Zank, Eastern Account System of Connecticut, Inc. c/o Boyd W. Gentry, Esq. All witnesses disclosed by any other parties.

C.

Witnesses A-C may be called upon to testify as to their knowledge of the facts, circumstances, and allegations surrounding Plaintiff's Complaint, including but not limited to Defendant's alleged actions and the damages alleged by Plaintiff in his Complaint. This

testimony may include but may not be limited to the facts and circumstances surrounding Defendant's correspondence and telephone communications with Plaintiff. They may also be called upon to testify to the qualifications and training of individuals involved in matters surrounding the allegations of Plaintiff's Complaint, which may include their own backgrounds, qualifications, and training. These individuals may also be called upon to testify as to the procedures and policies of Defendant. These individuals may also be requested to produce and 1

Case 1:07-cv-00410-MPT

Document 53

Filed 02/19/2008

Page 2 of 2

identify documents which may be relevant to the issues in this case. Defendant reserves the right to supplement its disclosures at a later time. 2. Documents, data compilations and tangible things that are in the possession, custody

or control of Defendant, that Defendant may use to support its claims or defenses: A. B. C. D. Defendant's collection notes relating to the accounts at issue. Sample Correspondence forwarded to Plaintiff Defendant's responses to Plaintiff's consumer dispute verifications Documents filed by Defendant Comcast Corporation, Inc, in support of its Motion for Summary Judgment.

3.

Computation of Damages Claimed by Defendant: Defendant has no disclosures to make at this time. Defendant specifically notes,

however, that by making no disclosure at this time, Defendant does not waive the right to seek attorney fees and costs from Plaintiff at a later time. 4. Insurance Agreement: Defendant is in possession of an insurance agreement between St. Paul Travelers Insurance Company and Defendant, and will make it available upon request. Defendant specifically reserves the right to supplement its disclosures as discovery proceeds. Respectfully submitted,

/s/ C. Scott Reese C. Scott Reese (DE Bar ID #2036) Cooch & Taylor, P.A. 824 North Market Street, Suite 1000 P.O. Box 1680 Wilmington, DE 19899-1680 (302) 984-3800 Email: [email protected] Attorney for Defendant Eastern Account System of Connecticut, Inc. Date: February 19, 2008 2