Free Response to Discovery - District Court of Delaware - Delaware

Case 1 :04-cv-00970-JJF Document 82 Filed O9/15/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
TERRY L. SNYDER, )
)
Plaintiff, ) C.A. N0. 04-9'70(JJF)
)
v. )
)
CITISTEEL USA, INC. )
)
)
Defendant. )
PLAINTIFF’S RESPONSES TO DEFENDANT’S
SECOND REQUEST FOR PRODUCTION
16. All pamphlets, notices, notes and other documents relating to the
employee benefits package at the Skelly Group, as requested during Plaintiffs
deposition.
RESPONSE: Plaintiff is not in possession of this information, nor has she been
in the past, either prior to, dtning or after her depositions.
17. Any and all correspondence, agreements, and other documents referring or
relating to your retention and dismissal of Thomas Neuberger, Esquire and his associates,
as requested during Plaintiff s deposition.
RESPONSE: Plaintiffs counsel objects to this request as the information
requested is protected under the attorney/client privilege and attorney work product.
Without waiving this objection, Plaintiff is not in possession of any of these documents
as they have been discarded.
18. All resumes and cover letters you provided to potential employers after
your employment with Defendant, indicating for each the (a) date the document was
created; and (b) date(s) the document was provided to potential employers.

Case 1:04-cv-00970-JJF Document 82 Filed O9/15/2006 Page 2 of 4
RESPONSE: Every cover letter in which Plaintiff was in possession has been
produced.
19. All documents received from potential employers or employment agency
during or after your employment with Defendant, including without limitation documents
relating to interviews, job offers, job information, _j ob rejection notices, "turn down
letters", or further inquiry following your submission ofa job application or resume,
received from a prospective employer, employment agency, employment search firm,
recruiter, temporary staffing firm.
RESPONSE: To the extent these documents exist and were in the control and/or
possession of Plaintiff, they have been produced.
20. All documents that indicate the availability of a Clerk/Typist or
comparable position in the Shipping Department in April 2003.
RESPONSE: Plaintiff is not now and has never been in possession of documents
that would indicate the availability of a Clerk/Typist or comparable position in the
Shipping Department in April 2003.
21. All documents identified or referred to, in your answers to Defendant’s
Second Set of interrogatories Directed to Plaintiff.
RESPONSE: To the extent these documents exist and were in the control and/or
possession of Plaintiff, they have been produced.
22. All documents identified or referred to, in your answers to Defendant’s
First Request For Admissions Directed to Plaintiff.
RESPONSE: To the extent these documents exist and were in the control and/or
possession of Plaintiff, they have been produced.

Case 1:04-cv-00970-JJF Document 82 Filed O9/15/2006 Page 3 of 4
23. Any other document or thing in your possession or available to you, in
addition to the items specified in previous sections of this Request for Production that is
relevant to any issue in the litigation, including but not limited to issues of liability andjor
damages and which has not been previously produced.
RESPONSE: To the extent these documents exist and were in the control and/or
possession of Plaintiff, they have been produced.
MARGOLIS EDELSTEIN
/s/ Lori A. Brewington
Jeffrey K. Martin, Esquire (#2407)
Lori A. Brewington, Esquire (#4522)
1509 Gilpin Avenue
Wilmington, Delaware 19806
Dated: September 15, 2006 (302) 777-4680 (Telephone)
Attorneys for Plaintiffs

Case 1:04-cv-00970-JJF Document 82 Filed O9/15/2006 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
TERRY L. SNYDER, )
)
Plaintiff, ) C.A. N0. 04-970(JJF)
)
v. )
)
CITISTEEL USA, INC. )
)
)
Defendant. )
CERTIFICATE OF SERVICE
1, Lori A. Brewington, do hereby certify that on September 15, 2006, 1
electronically tiled Pl¢1ir¢tgff’s Response to Defemlanfs Second Request For
Production with the Clerk of the Court using CM/ECF which will send notification of
such filing to the following:
Margaret M. DiBianca, Esquire
Sheldon N. Sandler, Esquire
Young Conaway Stargatt & Taylor LLP
1000 West Street, 17th Floor
P.O. Box 391
Wilmington, DE 19899-0391
MARGOLIS EDELSTEIN
/s/ Lori A. Brewington
Jeffrey K. Martin, Esquire (#2407)
Lori A. Brewington, Esquire (#4522)
1509 Gilpin Avenue
Wilmington, Delaware 19806
Dated: September 15, 2006 (302) 777-4680 (Telephone)
Attorneys for Plaintiffs