Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00092-JJF

Document 5

Filed 05/15/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JOANN KAYEA Plaintiff, v. THE PRUDENTIAL INSURANCE COMPANY OF AMERICA Defendant. : : : : : : : CIVIL ACTION

NO: 07-92 (JJF)

DEFENDANT PRUDENTIAL INSURANCE COMPANY OF AMERICA'S SELF-EXECUTING DISCLOSURES PURSUANT TO FRCP 26 Pursuant to the Federal Rule of Civil Procedure 26, Defendant Prudential Insurance Company of America, ("Prudential") through its attorneys, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, provides its initial disclosures as follows: A. 1. Individuals Likely to Have Information that Defendant May Use To Support its Defenses. Tara Johnson, ALHC Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Susan Larsen Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 James E. Furman Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Suzanne M. Posey Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Nina Ricci Prudential Insurance Company of America 751 Broad Street

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Newark, NJ 07102-3777 6. Susan Garcia Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Susan Henriques Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Paul Arbadji, PT Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Thomas Virgilio, CRC Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Nina Matias Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Douglas Palmer, CRC Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Gregg Schwartzkopf Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Richard Day, MD Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777

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The above named individuals were involved in the handling of Plaintiff's disability claim as reflected in the attached administrative record.

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B.

Description of Documents and Tangible Things That Defendant May Use to Support Its Defenses. Subjective Objective Analysis and Plan (SOAP NOTES). These are notes regarding Ms. Kayea's disability claim. Please see attached documents. Telephone Call Log. This is the log of incoming and outgoing telephone calls regarding Ms. Kayea's disability claim. Various correspondence to and from Prudential to Joann Kayea, Brandywine School District, and medical providers. Please see attached documents. Plaintiff's Complaint and Attachments. Please see attached documents. Medical records, notes, reports and correspondence from Dr. Buonocore. Please see attached medical records. Medical records, notes, reports and correspondence from Dr. Savinese. Please see attached medical records. Medical records, notes, reports and correspondence from Dr. Kim. Please see attached medical records. Medical records, notes, reports and correspondence from Dr. Bonner. Please see attached medical records. Supplementary Claimant Statement. Please see attached records. Vocational Rehabilitation Education and Employment History Form. Please see attached records. Prudential Financial Group Disability Insurance ­ Attending Physician's Statement (2003 and 2005). Please see attached documents. Group Disability Insurance Employer Statement. Please see attached documents. Group Disability Employee Statement. Please see attached documents. Pension Approval. Please see attached documents. Functional Capacity Evaluation. Please see attached documents. Job Description. Please see attached documents.

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