Free Motion to Compel - District Court of Delaware - Delaware

Case 1 :04-cv—01538-SLR Document 43-6 Filed 07/18/2005 Page1 012
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Case 1 :04-cv—01538-SLR Document 43-6 Filed 07/18/2005 Page 2 of 2
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June 15, 2005
Jayne A. Risk, Esquire
One Liberty Place
Iti50 Market Street, Suite 4900
Philadelphia, PA EQIO3
RE: Estate ofJo§m Vascek vs. United Parcel Service, etal
Dear Ms. Risk:
,. I still have not received Mark Bard’s verified responses to Plaintiffs First Set ot`
interrogatories. In our last conversation, tviien I told you that the answers must his own and
verified by him, you denied this and said "i\/like, we are in Federal court, not state court? In
that regard, I direct your attention to Federal Rule of Civil Procedure 33(b)(2), which provides,
inter alia,:
The answers are to be signed by the person making them,
_ and the objections signed by the attorney making them,
In our discussion, I made ctear that pursuant to Federal Rule of Civii Procedure
33(b)(2), the discovery responses you sent me are inadequate and in violation ofthe Ruies. To
be clear, these Interrogat-cries are to be answered by Mr. Bard himself, not his attorney. I will
not accept responses which were obviousty prepared by the defetidant dz·iver’s attorney, which
are not in his words, and are absent his verification. If you and your ctient do not feel bound to
comply with Rule 33, the appropriate motion wiil be filed.
iiinally, when Mr. Bard does answer the interrogatories, please make sure that they are
more complete and less evasive than your version of his answers.
V ery/[ ‘____,.... -»— p
MTV/Ec (Miehael T. van der Veen ,
I cc: Richard R. Weir. Jr., Esquire ,-*1
William Cattie, Esquire §