Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1:06-cv-00734-GMS

Document 35

Filed 05/14/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

WILLIAM JOSEPH WEBB, JR., Plaintiff, v. MINNER, et. al., Defendants.

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C. A. No. 06-734-GMS JURY TRIAL REQUESTED

1st REQUEST FOR PRODUCTION DIRECTED TO PLAINTIFF Defendant Raphael Williams hereby requests that Plaintiff produce at Defendant Williams' attorney's office for the purpose of inspection and copying, all of the following documents or evidence within 30 days pursuant to Fed.R.Civ.P. 34. These requests for production are continuing and the items requested must be kept current by supplementation. As used in this request for production, "you" or "yours" means and refers to plaintiff, his attorney(s) and their agents and employees. Defendant Williams requests Plaintiff produce complete originals of the following: 1. Any and all documents and tangible things referred to in Plaintiff's

complaints in this matter. 2. Any and all documents and tangible things identified or that should be

identified in response to Defendant Williams' interrogatories.

Case 1:06-cv-00734-GMS

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Filed 05/14/2008

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3.

Any and all reports, including drafts, by an expert retained by Plaintiff in

connection with this matter as well as his or her current qualifications, and any documents supplied or reviewed by that individual. 4. Any and all statements, in writing or oral, by any party or witness, in any

form, relating to the incidents that form the basis of this lawsuit. 5. Any and all videotapes, audiotapes, or photographs taken by you that

refers or relates to any claim or defense in the present matter. 6. Any and all medical records or reports regarding the examination or

treatment of Plaintiff. 7. Any and all documents or physical evidence that supports any claim of

Plaintiff for damages of any nature.

STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Catherine Damavandi Deputy Attorney General, ID #3823 Department of Justice 820 N. French Street, 6th Floor Wilmington, DE 19801 (302)577-8400 [email protected] DATED: May 14, 2008

Case 1:06-cv-00734-GMS

Document 35

Filed 05/14/2008

Page 3 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

WILLIAM JOSEPH WEBB, JR., Plaintiff, v. MINNER, et. al., Defendants.

) ) ) ) ) ) ) ) )

C. A. No. 06-734-GMS JURY TRIAL REQUESTED

CERTIFICATE OF SERVICE I hereby certify that on May 14, 2008, I electronically filed Defendant Raphael Williams' 1st Request for Production with the Clerk of Court using CM/ECF. I further certify that on May 14, 2008, I caused the within document to be mailed to the following non-registered participant by United States Postal Service: William J. Webb, Jr., SBI#256056 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977

/s/ Catherine Damavandi Deputy Attorney General, ID #3823 Department of Justice 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendant Raphael Williams