Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:04-cv-01025-KAJ

Document 20

Filed 11/02/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE In re: Case Nos. 01-11628 through 01-11639(PJW) Jointly administered Chapter 11

NationsRent, Inc. et al., Debtors. __________________________________ NationsRent Unsecured Creditor's Liquidating Trust, Perry Mandarino, Not Personally, but as Trustee, Plaintiff, v. Multiquip, Inc., Defendant. __________________________________

Case No. 04-1025

INITIAL DISCLOSURES OF MULTIQUP, INC., PURSUANT TO RULE 26(a)(1) OF THE FEDERAL RULES OF CIVIL PROCEDURE GOVERNING INITIAL DISCLOSURES Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, Defendant, Multiquip, Inc., by and through its undersigned counsel, hereby provides the following information: 1. The name and, if known, address and telephone number of each individual likely to have discoverable information that the disclosing party may use to support its claims or defenses, identifying the subjects of the information. RESPONSE: Jim Morse Multiquip, Inc. 18910 Wilmington Avenue Carson, California

Mr. Morse should only be contacted through counsel.

Case 1:04-cv-01025-KAJ

Document 20

Filed 11/02/2005

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2. A copy of, or a description by category and location of all documents, data compilations, and tangible things in the possession, custody or control of the party and that the disclosing party may use to support its claims or defenses.

RESPONSE: Invoices, contracts, bills of sale, bills of lading, payment history etc. Copies located in the possession and control of either counsel for Defendant, or Defendant Multiquip, Inc., at the location set forth above in Paragraph One above. Defendant reserves the right to supplement this response as its investigation progresses.

3. A computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 34 the documents or other evidentiary material, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of injuries suffered. RESPONSE: N/A 4. A copy of any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in the action or to indemnify or reimburse for payments made to satisfy the judgment. RESPONSE: N/A Dated: November 2, 2005 Wilmington, Delaware CROSS & SIMON, LLC

By:/s/ Judy M. Jones Judy M. Jones, Esquire (No. 3521) 913 North Market Street, 11th Floor P.O. Box 1380 Wilmington, Delaware 19899-1380 (302) 777-4200 (302) 777-4224 (Facsimile) Attorneys for Defendant, Multiquip, Inc.