Free Disclosure Statement - District Court of Delaware - Delaware

Case 1 :07-cv-00092-JJF Document 6 Filed 06/08/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOANN KAYEA, *
2%
Plaintiff, *
ic
v. _ * C.A. No. 07-092 (JJF)
TI-IE PRUDENTIAL INSURANCE *
COMPANY OF AMERICA, a foreign *
company, "‘
if
Defendant. *
PLAIN TIFF'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26§a)§ 1;
Plaintiff Joann Kayea, by and through her attorneys, Schmittinger and Rodriguez, P.A.,
hereby discloses the infomation required by Fed. R. Civ. P. 26(a)(l) to Defendants as follows:
I. Individuals likely to have discoverable information that Plaintiff may use to
support her claims or defenses:
The following are individuals likely to have discoverable information that Plaintiff may
use to support her claims, but not solely for impeachment,
l. Plaintiff Joann Kayea;
2. Glenn Kayea, Plaintiffs spouse;
3. James Bonner, M.D. of Physical Therapy Physicians;
4. Richard Buonocore, M.D. and Vidyadhar Chitale, MD. of Neurosurgical
Practice Associates;

Case 1:07-cv-00092-JJF Document 6 Filed 06/08/2007 Page 2 of 3
5. Stanley Savinese, D.O. of Crozer—Keystone Health System;
6. Physicians and other employees of PRO Physical Therapy.
II. Description of documents, data compilations, and tangible things that are in the
possession, custody, or control of Plaintiff that she may use to support her claims
or defenses:
The following are the documents, data compilations, and tangible things in the possession,
custody, or control of Plaintiff that Plaintiff may use to support her claims (but not solely for
impeachment) that have not been previously produced in any Pleadings or Briefing papers:
1. Medical records from Plaintiffs treating physicians;
2. Medical bills from Plaintiff s treating physician; U
3. Correspondence between client and State of Delaware State Board of Pension
Trustees and Office of Pensions;
4. Correspondence between Prudential Financial and Plaintiff.
]]I. Computation of Categories of Damages:
The categories of damages claimed by Plaintiff are as set forth in Plaintiff s Complaint.
Said damages are not subject to quantification at this point. Pecuniary damages, including future
losses, will be evaluated and analyzed. Vlfhen this process is completed, the particulars ofthe
loss will be provided to Defendant.
IV. Insurance:

Case 1:07-cv-00092-JJF Document 6 Filed 06/08/2007 Page 3 of 3
Pursuant to Fed. R. Civ. P. i6(a) (1) (D), Plaintiff has no known insurance.
SCHMITTINGER & RODRIGUEZ, P.A.
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BY: ff . - ". ‘ 5 J;
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_ ·/ ILLIAM D. FE _.TCI-IER, JR.
Bar LD. No. 362{ _.-t . I
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BY: 5 mv-{J . #
N EL`1>RiMos
Bar I.D. No. 3t24
414 S. State Street
P.O. Box 497
Dover, DE 19903-0497
(302) 674-0i40
Attorneys for Plaintiff
Dated: Q/G?
WDF/ljo

Case 1:07-cv-00092-JJF Document 6-2 Filed 06/08/2007 Page 1 of 1
CERTIFICATE OF SERVICE
l hereby certify thatl have caused copies of the following:
PLAINTIFF'S INITIAL DISCLOSURES MADE PURSUANT TO
FED. R. CIV. P. 26(a]{1)
to be served upon: I
Megan Harper, Esq.
Wilson, Elser, Moskowitz, Edelman & Dicker LLP
The Curtis Center, Suite 1130 East
Independence Square West
Philadelphia, PA 19106
by mailing copies to the address shown above, postage prepaid on QUML 8, 2[7U:rr .
SCHMITTINGER & RODRIGUEZ, P.A.
W KE - n )
D s i D ::‘._ 7
BY; ,·: ’ t »’ ,
I " ¥LLIAl\/I D. FL JCHER,
1.D. # 362 f
414 S. State Street {
P.O. Box 497
Dover, DE 19903-0497
(302) 674-0140
Attorneys for Plaintiff
DATED: é/igfqg
WDF/ljo