Free Interrogatories Propounded - District Court of Delaware - Delaware

Case 1:07-cv-00244-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HENRY R. TAYLOR, JR., Plaintiff, v. KATHLEEN D. FELDMAN, et al., Defendants. : : : : : : : : :

C.A.No. 07-244-JJF

FELDMAN'S 1st SET OF INTERROGATORIES DIRECTED TO PLAINTIFF Defendant Kathleen D. Feldman hereby requests that plaintiff fully answer, in writing and under oath, each of the following interrogatories within 30 days of receipt pursuant to Fed.R.Civ.P. 33. These interrogatories are continuing and the information requested must be kept current by supplementation. As used in these interrogatories, "you" or "yours" means and refers to the plaintiff, his agents and employees.

Case 1:07-cv-00244-JJF

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INTERROGATORIES 1. Identify by name, address, and telephone number all persons with

knowledge of the facts as to each allegation as set out in your complaint(s) and identify those persons that have been interviewed on your behalf and as to the interview, state: the date, the location, the subject matter and any documents discussed, identified or provided by that person. Answer:

-2-

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2.

Identify each and all documents or other items of evidence that you intend

to use in this lawsuit, for any purpose, including, but not limited to crossexamination, during any pretrial or trial proceedings. Answer:

-3-

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3.

For each allegation you are presenting in this matter, state with particularity

and specificity (please provide the complete details including dates, times, and locations) the complete factual basis for each allegation and identify all persons having knowledge as well as each and all documents or other items of evidence in your possession that relate to each claim. Answer:

-4-

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4.

State and identify by names of parties, court or administrative body and

case number all lawsuits or legal proceedings, at law or equity, of any nature in which you were a party and the disposition of that matter. Answer:

-5-

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5.

Identify by name, address, phone number, location, date and persons

present, all individuals that have been interviewed by you in connection with this matter and whether any documents or memorandum were prepared relating to that interview. Answer:

-6-

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6.

Identify each and all photographs, videotapes, audio tapes or any other

form of recording media that relate to this matter, and state the time, date, location and manner that such were made as well as the names of all individuals that have the originals or copies. Answer:

-7-

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7.

Regarding your employment history, list in chronological order the names

of all your employers, location of the job, position or duties of position and inclusive periods of such employment to the present time. Answer:

-8-

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8.

List in chronological order all of your formal education. Please include the

name and address of each educational institution or school, the dates of your attendance and the degree(s) awarded. Answer:

-9-

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9.

To the extent you have previously made the claims that are set forth in your

complaint, please state and identify the resolution of that matter, the name of the court, judge, case number and date of the decision. Answer:

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STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Marc P. Niedzielski Marc P. Niedzielski (#2616) Deputy Attorney General 820 North French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 Attorney for Defendant DATED April 3, 2008 VERIFICATION I, Henry R. Taylor, Jr., do verify that under the penalty of perjury pursuant to 28 U.S.C. § 1746 that the above responses to defendant's interrogatories are true and correct.

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CERTIFICATE OF SERVICE I certify that on the date indicated below I served two copies of the attached document by regular U.S. Mail on the following: Henry R. Taylor, Jr. SBI 00159464 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977

/s/ Marc P. Niedzielski Marc P. Niedzielski (2616) Deputy Attorney General Department of Justice 820 North French Street Carvel Building, 6th Floor Wilmington, DE 19801

DATED: April 3, 2008 - 12 -