Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00117-IVIPT Document 21 Filed 06/29/2007 Page 1 of 3
IN THE DISTRICT COURT OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
TAMMY HURD, :
Plaintiff, 2
v. C.A. No.: 07-117
DELAWARE STATE UNIVERSITY
and DANDESON PANDA, individually :
and in his official capacity, :
Defendants.
DEFENDANT PANDA’S RULE 26 DISCLOSURES
DANDESON PANDA ("Panda") hereby provides the initial disclosures required by Fed.
R. Civ. P. 26(a)( 1). These disclosures are based on information reasonably available to Panda as
of the date these disclosures are served. Panda reserves the right to supplement these disclosures
pending additional investigation and discovery and as permitted by Fed. R. Civ. P. 26(e).
A. The name and, if known, the address and telephone number of each individual
likely to have discoverable information that the disclosing party may use to support its claims or
defenses, unless solely for impeachment, identifying the subjects of the information:
RESPONSE: At this time:
Dandeson Panda
Allen Sessoms
Mark Farley
B. A copy of, or a description by category and location ot, all documents, data
compilations and tangible things in the possession, custody or control of the party and that the
disclosing party may use to support the disclosing party’s claims or defenses, unless solely for
impeachment:

Case 1 :07-cv-00117-IVIPT Document 21 Filed 06/29/2007 Page 2 of 3
RESPONSE: At this time Defendant Panda is not in possession of any documents
responsive to this question.
C. A computation of any category of damages claimed by the disclosing party,
making available for inspection and copying, as under Rule 34 the documents or other
evidentiary material not privileged or protected from disclosure, on which such computation is
based, including materials bearing on the nature and extent of injuries suffered.
RESPONSE:
Not applicable.
D. For inspection and copying, as under Rule 34, any insurance agreement under
which any person carrying on an insurance business may be liable to satisfy part of all of a
judgment which may be entered in the action or to indemnify or reimburse for payments made to
satisfy the judgment.
RESPONSE:
At this time Defendant Panda is unaware of any insurance agreements that may
be applicable to this action.
RICHARD R. WIER, JR., P.A.
/s/Richard R. Wier, Jr.
Richard R. Wier, Jr. (#716)
Two Mill Road - Suite 200
Wilmington, DE 19806
(302)888—3222

Case 1 :07-cv-00117-IVIPT Document 21 Filed 06/29/2007 Page 3 of 3
IN THE DISTRICT COURT OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
TAMMY HURD, :
Plaintiff,
: C.A. No.: 07-117
v. :
DELAWARE STATE UNIVERSITY and
DANDESON PANDA, individually and in :
his official capacity, :
Defendants.
CERTIFICATE OF SERVICE
I hereby certify that on this 29‘“ day of June 2007 that I served the Plaintiff, TAMMY
HURD the attached RULE 26 DISCLOSURES by ELECTRONIC
FILING on:
Ronald G. Poliquin, Esq. Marc Stephen Casarino, Esq.
Young, Malmberg & Howard, P.A. Whit & Williams, LLP
30 The Green 824 Market Street - suite 902
Dover, DE 19901 Wilmington, DE 19899-0709
/s/ Richard R. Wier, Jr.
Richard R. Wier, I r. (#716)
Two Mill Road - Suite 200
Wilmington, DE 19806
(302)888-3222
Attorney for Plaintiff
Dandeson Panda