Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07—cv—00078-JJF Document 15 Filed 06/01/2007 Page 1 of 3
IN TI-IE UNITED STATES DISTRICT COURT
FOR THE DISTRICT GF DELAWARE
SAMI ALMAKI-IADHI, )
) .
Plaintiff, ) Civ. A. No. . 07—78~JJlF
E I )
v. )
‘ )
DELAWARE PARK, )
j )
A Defendant, )
INITIAL DISCLOSURES OF DEFENDANT
DELAWARE PARK, L.L.C. PURSUANT TO RULE 26ga[(1; _
Defendant Delaware Park, L.L.C. ("Delaware Parl<"), by and through its
undersigned attorneys, hereby makes the following disclosures, pursuant to Federal Rule
of Civil Procedure 26(a)(l ).
(A) lndividuals likely to have discoverable information that Defendant may use
to support its claims or defenses, and the subjects of the information:
A Response:
Individual Areas of Knowledge
Sami Almakhadlti All aspects of Plaintiff s claims.
Current management employees of Delaware Park may be contacted through the
undersigned counsel or at Delaware Park. Fenner management employees of Delaware
Park may be contacted through the undersigned counsel or at the address provided below:
_ Shannon DeLucia Plaintiffs work restrictions and request for light duty.
Plaintiffs worker’s compensation claim. Defendantfs
light duty program; grants or denials of light duty to
other employees. Plaintiff s termination from
employment.

Case 1 :07-cv-00078-JJF Document 15 Filed 06/01 /2007 Page 2 of 3
Karlyn Dixon Plaintiffs job perfonnance. Plaintiffs performance
evaluation. Plaintiff s internal complaints and
resolution thereof. Hiring decision regarding impress
l Supervisor position in August 2005.
{ Beverly Pope Plaintiffs application and interview for impress
Supervisor. Hiring decision regarding impress
Supervisor position in August 2005.
, Stacy Suhr Plaintiffs application for Impress Supervisor. Hiring
decision regarding lrnpress Supervisor position in
2 August 2005. Plaintiff s performance evaluation.
Plaintiff s internal complaints and resolution thereof
Frank Penta Plaintiff s internal complaints and resolution thereof.
Sheryl Cartwright Plaintiff s work restrictions. Defendanfs iight duty
A program; grants or denials of light duty to other
employees.
Micki Nardo Delaware Park’s investigation of Plaintiff s internal
120 Talbot Drive complaints and resolution thereof.
Landenberg, PA 19350
E Tel. (610) 255-5004
Delaware Park reserves the right to identify other individuals as its investigation
continues.
(B) Documents, data, compilations and tangible things in the possession,
in custody, or control of Defendant that Defendant may use to support its claims or
defenses:
l Response:
l. Plaintiff Sami Almaldiadhfs personnel file, maintained in hard copy;
2. Job description for Impress Supervisor as of August 2005, maintained by Delawme
E Park in electronic form and/or in hard copy;
3. Communications regarding Plaintiffs medical status, work restrictions and request
§ for light duty, maintained by Delaware Park in electronic form and/or in hard copy;

Case 1 :07-cv-00078-JJF Document 15 Filed 06/01/2007 Page 3 of 3
4. Communications regarding Plaintiff s internal compiaints of discrimination to
Defendant, the ensuing investigation(s), and Defendant’s response to Plaintiff s
complaints, maintained by Delaware Park in electronic form and/or in hard copy;
5. Documents regarding Piamtiff s termination from employment, maintained by
Delaware Park in electronic form and/or in hard copy;
D 6. Documents related to the termination of employees who, like flaintiff, had
E exhausted all available leave, maintained in eiectronic form and/or hard copy.
Delaware Park reserves the right to identify other categories of documents as its
j investigation continues. (
(C) A computation of any category of damages claimed by Defendant:
Response: None.
(D) Insurance agreements under which any person or entity carrying on an
insurance business may be liable to satisfy part or all of a judgment which may be entered
_
in this action, or to indemnify or reimburse defendant for payments made to satisfy the
judgment:
Response: None.
POTTER >. B . RSON & CORR
Bri ( ( (K ( ‘
j wana 142)
? Jennifer . · (#4933)
Hercules Piaza, Sixth Floor
E3 l 3 North Market Street
_ PD. Box 951
Wilmington, DE 19899
(302) 984-6000
[email protected]
l [email protected]
Attorneys for Defendant Delaware Park,
L.L. C.
Dated: June i, 2007
796245

Case 1:07-cv-00078-JJF Document 15-2 Filed 06/O1/2007 Page 1 of 1
CERTIFICATE OF SERVICE
1, Wendy K. Voss, hereby certify this lst day of June, 2007, that the
foregoing INITIAL DISCLOSURES OF DEFENDANT DELAWARE PARK,
L.L.C. PURSUANT T0 RULE 26(a)(1) was electronically filed with U.S. District
Court District of Delaware via CM/ECF (Official Court Electronic Document Filing
System) and two (2) true and correct copies were sent First Class U.S. Mail, postage
prepaid, to the following:
{ Sami Almakhadhi
200 W. Creek Village E6
Elkton, MD 21921
E
e r
Wendy K Voss (#314
POTTER NDERSO & CORROON LLP
1 A Hercules Pla , ` Floor
f 1313 North Market Street
PD. Box 951
Wilmington, DE 19899
(302) 984-6000 ·~ Telephone
(302) 658-1192 — Facsimile
WVOSS§@,QO[l€f&Hd€ISOH.CO1'1`1