Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00283-GMS

Document 26

Filed 01/14/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

M.C. PAINTING CORPORATION Plaintiff, v. CIANBRO CORPORATION, and TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA Defendants

: : : : No. 1:07-cv-283 (GMS) : : : : : : : :

PLAINTIFF'S INITIAL DISCLOSURES PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 26(a)(1) Pursuant to Federal Rule of Civil Procedure 26(a)(1), Plaintiff, M.C. Painting Corporation, through its undersigned counsel, hereby submits the following Initial Disclosures. A. Individuals Likely to Have Discoverable Information Concerning the Claims and Defenses In This Action

Plaintiff believes the following are likely to have discoverable information on its behalf concerning the claims in this action: 1. Van Calombaris, President M.C. Painting Corporation 1195 Haverford Road Crum Lynne, PA 19022

Plaintiff reserves its right to supplement this list up to and including the time for trial if additional information becomes available.

Case 1:07-cv-00283-GMS

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Filed 01/14/2008

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B.

Documents and Things in the Possession, Custody or Control of Plaintiff or Plaintiff's Counsel

Plaintiff maintained a file for the construction project that is at issue in this action. Said file contains all of the documents pertinent to the claims and defenses raised herein and is available for inspection and copying upon the request of the Defendants.

C.

Calculation of Damages

Plaintiff seeks $93,690.15 for work performed at the project at issue in this action, which is calculated as follows: Original Contract Amount Additional Work done on Time and material basis Subtotal Payments to Date Balance D. Insurance Agreements $529,225.00

29,727.58 $558,952.58 (465,262.43) $93,690.09

There are no insurance agreements within the scope of Rule 26(a)(1)(D) relevant to this matter, to the best of Plaintiff's knowledge.

DAVIS, BUCCO & ARDIZZI

/s/ Robert D. Ardizzi, Esquire Delaware Bar I.D. No. 3602 901 N. Market Street, Suite 700 Wilmington, DE 19801 (302) 345-9808 [email protected] Attorney for Plaintiff Date: January 14, 2008

Case 1:07-cv-00283-GMS

Document 26-2

Filed 01/14/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

M.C. PAINTING CORPORATION Plaintiff, v. CIANBRO CORPORATION, and TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA Defendants

: : : : No. 1:07-cv-283 (GMS) : : : : : : : :

CERTIFICATE OF SERVICE I herby certify that true and correct copies of Plaintiff's Disclosures Pursuant to Rule 26(a)(1) were served upon counsel for the Defendants via electronic mail on January 14, 2008 at the following addresses: Sandra G.M. Selzer, Esquire Greenberg Traurig, LLP The Nemours Building 1007 North Orange Street, Suite 1200 Wilmington, DE 19801 [email protected] Christopher Alan Selzer, Esquire McCarter & English Renaissance Centre 405 N. King Street, 8th Floor Wilmington, DE 19801 [email protected] DAVIS BUCCO & ARDIZZI BY: /s/ Robert D. Ardizzi, Esquire Robert D. Ardizzi, Esquire Bar I.D. No. 3602 901 N. Market Street, Suite 700 Wilmington, DE 19801 (302) 345-9808 [email protected]

Date: January 14, 2008