Free Interrogatories Propounded - District Court of Delaware - Delaware

Case 1:04-cv-00419-JJF

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Filed 09/22/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CATHY D. BROOKS-MCCOLLUM, ) ) Plaintiff, ) ) v. ) ) STATE FARM INSURANCE COMPANY, ) ) Defendant. )

Civil Action No. 04-419 JJF

DEFENDANT'S INTERROGATORIES TO PLAINTIFF

1.

Identify by name and address all persons who vandalized any property of the plaintiff and

state with specificity what was vandalized, and when the vandalism occurred. ANSWER:

2.

Identify all persons by name and address who witnessed any act of vandalism to the

plaintiff's property. ANSWER:

3.

Identify all persons who in any manner harassed the plaintiff concerning matters relating

to any of her lawsuits. ANSWER:

4.

Identify any person who witnessed any harassment of the plaintiff or of her family

members. ANSWER:

Case 1:04-cv-00419-JJF

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5.

With regard to your claim that State Farm was involved with criminal activity, identify

each and every fact supporting your position to include the names and addresses of all persons who will testify that State Farm funded, either directly or indirectly, any criminal activity or was involved in any criminal activity involving the plaintiff. ANSWER:

CASARINO, CHRISTMAN & SHALK /s/ Stephen P. Casarino STEPHEN P. CASARINO, ESQ. I.D. No. 174 800 N. King Street, Suite 200 Wilmington, DE 19899-1276 (302) 594-4500 Attorney for the Defendant DATED: September 22, 2005

Case 1:04-cv-00419-JJF

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Filed 09/22/2005

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CERTIFICATE OF SERVICE

I, STEPHEN P. CASARINO, ESQ., hereby certify that I have caused to be deposited in the mailbox at 800 North King Street, Suite 200, Wilmington, DE 19801, on this 22nd day of September 2005, a true and correct copy of the attached Defendant's Interrogatories to Plaintiff to: Cathy D. Brooks-McCollum P.O. Box 12166 Wilmington, DE 19850

CASARINO, CHRISTMAN & SHALK

/s/ Stephen P. Casarino, Esq. STEPHEN P. CASARINO, ESQ. I.D. No. 174 800 N. King Street, Suite 200 Wilmington, DE 19899-1276 (302) 594-4500 Attorney for the Defendant