Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :07-cv—OO283-GIVIS Document 32 Filed O3/06/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF DELAWARE
M.C. PAINTING CORPORATION )
)
Plaintiff )
v. )
) Case N0. 07-283 (GMS)
CIANBRO CORPORATION, )
)
and )
)
TRAVELERS CASUALTY AND )
SURETY COMPANY OF AMERICA )
)
Defendants )
DEFENDANT c1ANBRo coR1>oRA*r1oN’s AMEN])ED DISCLOSURES
PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 26ga]g1[
COMES NOW, Cianbro Corporation ("Cianbro"), by and through undersigned counsel
pursuant to Federal Rule of Civil Procedure 26(a)(1) with this initial disclosure and states as
follows:
A. Parties Likely to Have Discoverable Information Concerning Claims and
Defenses in this Action:
Tom Stone
Cianbro Corporation
605 Pittman Road
Baltimore, MD
Mike Hart
Cianbro Corporation
605 Pittman Road
Baltimore, MD
Cianbro reserves the right to update his list.
B. The Location of Documents and Records Likely to be of Assistance in the
Litigation of all Claims and Counter-Claims:
ME1 70s2094v.1

Case 1:07-cv—OO283-G|\/IS Document 32 Filed O3/06/2008 Page 2 of 2
Cianbro maintains a file for the South Market Street Bridge project at its offices in
Baltimore Maryland. Files and records related to this matter are also maintained in the office of
Cianbro’s general counsel as well as with its outside counsel, McCa1ter & English, LLP.
C. A Calculation of Damages:
Cianbro’s counter-claim alleges damages of at least $52,766,@ calculated as follows:
Total monthly monitoring costs through warranty period: $32,247.00
Cost of Warranty Bond Purchased by Cianbro $7,545.00
Overcharges by M.C. Painting Corporation and amounts
Owed to or Offset by Cianbro $12,974.00
Cianbro asserts that additional potential damages exist to the extent that Cianbro, through
the end of the warranty period for which M.C. Painting Corporation was responsible but for
which M.C. Painting Corporation failed to secure the appropriate warranty bond for, is required
to perform any repair or replacement work to any of M.C. Painting Corporation’s work.
D. Insurance Coverage Relevant to this Matter:
No insurance coverage is relevant to P1aintiffs’ claims.
McCARTER & ENGLISH, LLP
/s/ Christopher A. Selzer
Christopher A. Selzer, Esq. (#4305)
405 N. King Street, 8th Floor
Wilmington, DE 19801
(302)-984-6300
(302)-984-6399 facsimile
Attorney for Defendant
Cianbro Corporation
Date: January 15, 2008
ME1 7052094v.i