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

Case 1:04-cv-01286-JJF

Document 12

Filed 03/01/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KARI M.(SMITH)PRILLER, ) ) Plaintiff, ) ) v. ) ) TOWN OF SMYRNA, DAVID S. ) HUGG, III, individually and ) in his official capacity as ) Town Manager; ) BEVERLY A. HIRT, individually ) and in her official capacity ) as Director of the Smyrna ) Public Library; and ) HARVEY LEGGETT, individually ) and in his official capacity ) as Supervisor of Streets/ ) Foreman of Public Works, ) ) Defendants. )

C.A. No. 04-1286-JJF

DEFENDANTS' FIRST REQUEST OF PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF 1. Any documents, writings, memoranda, data,

correspondence and/or tangible things which plaintiff or plaintiff's counsel relies upon or intends to rely upon to support the allegation that defendants discriminated against plaintiff on the basis of her sex and/or race. 2. Any documents, writings, meoranda, data, correspondence

and/or tangible things which plaintiff or plaintiff's counsel relies upon or intends to rely upon to support the allegation that as a result of the defendants' actions plaintiff has sustained severe emotional distress, pain and suffering, mental

1

Case 1:04-cv-01286-JJF

Document 12

Filed 03/01/2005

Page 2 of 2

anguish, humiliation and lost wages. 3. Any documents, writings, memoranda, data,

correspondence and/or tangible things which plaintiff or plaintiff's counsel relies upon or intends to rely upon to support the allegation that defendants refused to afford plaintiff due process.

AKIN & HERRON, P.A. /s/ Bruce C. Herron Bruce C. Herron (ID # 2315) 1220 N. Market Street Suite 300 P.O. Box 25047 Wilmington, DE 19899 (302) 655-5552 Attorney for Defendants Dated: March 1, 2005

2