Free Motion for Disclosure - District Court of California - California

Case 3:07-cv-04795-PJH

Document 15

Filed 12/03/2007

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CHARLES J. KATZ, ESQ. (SBN: 68459) 475 El Camino Real, Suite 300 Millbrae, California 94030 Telephone: (650) 692-4100 Facsimile: (650) 692-2900 Attorney for Defendant ZHAO HONG MIAO incorrectly sued as MIAO ZHAO HONG

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

ANDI MILLARD, Plaintiff, vs. CHEF KING RESTAURANT; MIAO ZHAO HONG dba CHEF KING RESTAURANT; HENRY L. BRYANT; ANNE BRYANT; and DOES 1-10, inclusive, Defendants. ___________________________________/

Case No. C07-04795 BZ DEFENDANT'S INITIAL DISCLOSURE [Federal Rule of Civil Procedure 26 and Local Rule 16-5]

Pursuant to Federal Rule of Civil Procedure §26 and Local Rule 16-5, Defendant Zhao Hong Miao makes the following initial disclosure of information and documents. Defendant's disclosure is made to the best of Defendant's counsel's present knowledge, information and belief, formed after an inquiry that is reasonable under the circumstances, and the disclosure is complete and correct as of the time it is made. Therefore, the below responses are all times subject to such additional or different information that discovery further investigation may disclose. A. Witnesses: Defendant as of this date has ascertained that the following 1

Defendant's Initial Disclosure

Case 3:07-cv-04795-PJH

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Filed 12/03/2007

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individuals are likely to have discoverable information relevant to disputed facts regarding discrimination: Lay Witnesses: 1. B. Zhao Hong Miao

Identify of Documents Under F.R. Civ. Proc. 23(a)(1)(B). Defendant is not

aware of any writings which may be relevant to disputed facts alleged in the Complaint, and which tend to support the position that Defendant is reasonably likely to take in the case. C. D. Insurance Agreements: None to Defendant's knowledge. Damages Computation: Defendant contends that Plaintiff has not been damaged

in any manner whatsoever.

Respectfully submitted.

Dated: November 30, 2007

CHARLES J. KATZ /s/ CHARLES J. KATZ, Attorney for Defendant MIAO ZHAO HONG

Defendant's Initial Disclosure

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