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

Case 1:04-cv-01417-GMS

Document 45

Filed 05/07/2007

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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE RICHARD C. HUNT, Plaintiff, v. FIRST CORRECTIONAL MEDICAL SERVICES, et al. Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 04-1417 ***

JURY OF 12 DEMANDED

REQUEST FOR PRODUCTION DIRECTED TO PLAINTIFF BY DEFENDANT FIRST CORRECTIONAL MEDICAL The defendant requests the plaintiff to produce for examination and copying at the office of the attorney for defendant on or before thirty (30) days from receipt of this Request: 1. All documents referred to in Plaintiff's Answers to Interrogatories filed simultaneously hereto. 2. Copies of all documents which are relevant, in whole or in part, to plaintiff's claims for

medical malpractice, Eighth Amendment violations and deliberate indifference. 3. Copies of all documents which are relevant, in whole or in part, to plaintiff's claims

of special and general damages (including future lost wages claimed). 4. the present. 5. Copies of all bills and receipts evidencing payment of bills for which the plaintiffs seek Please produce your Federal and State income tax returns for the years 1996 through

compensation in this lawsuit. 6. Copies of the curriculum vitae and reports of all experts you intend to call at trial.

Case 1:04-cv-01417-GMS

Document 45

Filed 05/07/2007

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MCCULLOUGH & MCKENTY, P.A. /s/ Dana Spring Monzo Daniel L. McKenty, Del. Bar No. 2689 Dana Spring Monzo, Del Bar No. 4605 1225 N. King Street, Suite 1100 P.O. Box 397 Wilmington, DE 19899-0397 (302) 655-6749 Attorney for Defendant First Correctional Medical May 7, 2007

Case 1:04-cv-01417-GMS

Document 45

Filed 05/07/2007

Page 3 of 3

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE RICHARD C. HUNT, Plaintiff, v. FIRST CORRECTIONAL MEDICAL SERVICES, et al. Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 04-1417 ***

JURY OF 12 DEMANDED

CERTIFICATE OF SERVICE I certify that, on this date, one copy of the attached Request for Production Directed to Plaintiff by Defendant First Correctional Medical was served on the following individual:

Via First Class Mail Richard C. Hunt SBI# 274714 Delaware Correctional Center 1181 Paddock Rd. Smyrna, DE 19977 Via Electronic Service Eileen Kelly, Esquire Department of Justice 820 N. French St., 6th Fl. Wilmington, DE 19801

/s/ Dana Spring Monzo Dana Spring Monzo, Del Bar No. 4605 May 7, 2007