Free Answer to Interrogatories - District Court of Delaware - Delaware

Case 1:04-cv-00970-JJF Document 81 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. 04-970(JJF)
)
v. )
)
CITISTEEL USA, INC. )
)
)
Defendant. )
PLAINTIFF’S ANSWERS TO DEFENDANT’S SECOND SET OF
INTERROGATORIES
22. Identify any and all sources of income you have received since the end of
your employment with CitiSteel including the name, address, and telephone number of
each source including but not limited to any employer, government agency, family
member or relative, welfare, charitable, or religious organization, or other source and,
with specificity, identify the amount of such wages.
ANSWER: After employment with CitiStee1, Plaintiff was employed through
Bernard temporary agency and most of her employment was coordinated through them.
At the time she was working with Bernard, she did have assignments with: The Franklin
Company in approximately August and September 1994; American Flag Company in
approximately April and May 2005; Abacus Consulting in approximately June 1995;
Delaware Temporary Systems in approximately November, December 2004 and January
and March 2005; Bayshore Ford and Truck and Vintage Properties, LLC over a short
period of time in 2005. Plaintiff also worked for the Skelly Group, 610 West State Street,
Media, Pennsylvania from approximately January through March 2006, but did not
complete the 90-day probationary period and did not get offered any kind of benefits, nor

Case 1 :04-cv-00970-JJF Document 81 Filed O9/15/2006 Page 2 of 4
was she given any company literature. Copies of pay stubs have been provided in
previous production as well as tax returns. Plaintiff is not in possession of any further
employment documentation which has not already been produced. Additionally, Plaintiff
did collect unemployment for a period of approximately 39 months after her termination
with Citi-Steele. Additionally, since being terminated from CitiSteel on occasion
Plaintiff does receive moneys from her father which helps her with expenses. She does
receive occasional payments of approximately $300 at a time but has not received any
money from her father for approximately the last two months.
23. Identify all job interviews you have attended since the end of your
employment with CitiSteel including the name of the potential employer, the date(s) on
which you applied for such employment, how you applied for such employment, how, by
whom, and when you were contacted about the interview, the date(s) of the interview(s),
the location of the interview(s), and the name of the interviewer(s), and the outcome of
the interview.
ANSWER: Plaintiff objects to this interrogatory as overbroad, unduly
burdensome and not meant to lead to relevant discoverable information. Without
waiving its objection, Plaintiff asserts that all responsive documents, based on
information and belief have previously been produced. Plaintiff does recall having gone
on approximately 10-20 interviews through Bernard temporary services and/or Matrix
temporary services, but cannot recall the names of those companies other than the Blood
Bank of Delaware on Hygeia Drive, and Allstate Insurance Company, Route 40,
Wilmington, Delaware. Plaintiffs attempts at obtaining any of those jobs were
unsuccessful.

Case 1 :04-cv-00970-JJF Document 81 Filed O9/15/2006 Page 3 of 4
24. Identify the circumstances surrounding your initial diagnosis of Hepatitis-
C, including the date of the initial diagnosis, the health care provider(s) who made such
diagnosis, the diagnosed cause, and the course of treatment and medicine that were
prescribed.
ANSWER: ln either July 2003 or 2004, Plaintiff had a blood test ordered by
her primary care physician, Dr. Ronald Goodman of Total Care Physicians, and she was
diagnosed by Dr. Goodman at that time. Dr. Goodman did not recommend any
treatment and referred Plaintiff to Stacy Manichek, M.D., another Delaware Physician
(who no longer practices in Delaware, but is allegedly practicing in Pennsylvania). ln
approximately January 2005, Dr. Manichek began a treatment of medication and
injections (one of which was Interferon) on a daily basis and this continued until
approximately March 2006, when Dr. Manicheck determined that Plaintiffs condition
U had gone into remission. As of that time, Plaintiff has not been on any medications for
this condition, nor has she seen any medical providers for this condition.
25. Identify your qualifications, skills and experience for an administrative or
secretarial position including but not limited to your computer abilities, your familiarity
and experience with standard software programs such as Microsoft Office, your typing
skills (in number of words per minute, including the date such skills were last assessed
and by whom they were assessed), and any other similar abilities.
ANSWER: Plaintiff is knowledgeable in the operation of the following
computer programs: Microsoft Excel, Word; Lotus; Corel Word Perfect and has been

Case 1 :04-cv-00970-JJF Document 81 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. No. 04-970(JJF)
)
v. )
)
CITISTEEL USA, INC. )
)
)
Defendant. )
CERTIFICATE OF SERVICE
I, Lori A. Brewington, do hereby certify that on September 15, 2006, I
electronically tiled Plaintwk Answers t0 Dq"endant’s Second Set oflnterrogatories
with the Clerk of the Court using CM/ECE which will send notification of such tiling to
the following:
Margaret M. DiBianca, Esquire
Sheldon N. Sandler, Esquire
Young Conaway Stargatt & Taylor LLP
1000 West Street, 171]] 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