Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:08-cv-00185-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DENISE BOWERS, Plaintiff, v. CITY OF WILMINGTON, a municipal government; MONICA GONZALEZ GILLESPIE, individually and in her official capacity as the Director of Personnel for the City of Wilmington; and FRANKLIN AMPADU, M.D., individually and in his official capacity as the Police Surgeon for the City of Wilmington, Defendants. : : : : : : : : : : : : : : : :

Civil Action No.

08-185 JJF

RULE 26(a) DISCLOSURES OF PLAINTIFF 1. The name and, if known, the address of each individual likely to have discoverable

information that the disclosing party may use to support its claims or defenses, unless solely for impeachment, identifying the subjects of the information. RESPONSE: Monica Gonzalez Gillespie 800 N. French Street Wilmington, DE 19801 Franklin Ampadu, M.D. 500 Wilmington Avenue Wilmington, DE 19801 Nellie Moore, R.N. 500 Wilmington Avenue Wilmington, DE 19801 Alex J. Mili, Esq. 800 N. French Street Wilmington, DE 19801 Jenny Hinkle 800 N. French Street Wilmington, DE 19801

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Mary McDermott 800 N. French Street Wilmington, DE 19801 Marcelle Basnight 800 N. French Street Wilmington, DE 19801 Police Chief Michael J. Szczerba 300 N. Walnut Street Wilmington, DE 19801 Greg Ciotti 300 N. Walnut Street Wilmington, DE 19801 Robert Williams 300 N. Walnut Street Wilmington, DE 19801 Daniel Sullivan 300 N. Walnut Street Wilmington, DE 19801 Bruce Mulrine 300 N. Walnut Street Wilmington, DE 19801 Amy Rausch 300 N. Walnut Street Wilmington, DE 19801 Henry Supinski 300 N. Walnut Street Wilmington, DE 19801 Nancy Dietz 300 N. Walnut Street Wilmington, DE 19801 Ruth Townsend 300 N. Walnut Street Wilmington, DE 19801 Cynthia A. Heldt, M.D. 3301 Lancaster Pike, Suite 9 Wilmington, Delaware 19805

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David C. Stephens, M.D. 2700 Silverside Road, Suite 1-A Wilmington, Delaware 19810 The below can be reached through counsel for the plaintiff. Denise Bowers Harold Carter Jordan Chambers

2.

A copy of, or a description by category and location of, all documents, data

compilations, and tangible things that are in the possession, custody, or control of the party and that the disclosing party may use to support its claims or defenses, unless solely for impeachment. RESPONSE: The following items in the possession of answering plaintiff's counsel: Report of Follow Up Evaluation Dated January 31, 2008. Letters from Monica Gonzalez-Gillespie Dated February 21, 2007, March 9, 2007, August 2, 2007, September 14, 2007, and January 23, 2008. Letters to Monica Gonzalez-Gillespie Dated August 10, 2007 and July 27, 2007 Copy of job description and medical records included in the January 23, 2008 letter sent to Dr. Heldt. Letter from Franklin Ampadu, M.D. Dated July 16, 2007. Letter from Dr. Cynthia A. Heldt, M.D. Dated September 11, 1007. Letter from Dr. David C. Stephens, M.D. Dated February 8, 2008. Letters from Mary Jo McLaughlin Dated July 11, 2007 and May 29, 2007. Letter to Mary Jo McLaughlin Dated July 3, 2007. Letters from Police Chief Michael J. Szczerba dated March 15, 2007, July 24, 2007, and February 1, 2008. Official Opinion of the Police Pension Board of Directors. Police Pension Board of Directors' Hearing Plaintiff's Exhibits A through G. Letter to Robert Williams Dated March 20, 2008. Letter to Alex Mili, Esq. Dated December 28, 2007.

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: Not applicable at this time. 4. For inspection or copying, as under Rule 34, any insurance agreement under which

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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: Not applicable.

RONALD STONER, P.A.

/s/ Ronald Stoner Ronald Stoner, Esq., DE 2818 1107 Polly Drummond Plaza Newark, DE 19711 (302) 369-6400 Attorney for Plaintiff

DATED: June 5, 2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DENISE BOWERS, Plaintiff, v. CITY OF WILMINGTON, a municipal government; MONICA GONZALEZ GILLESPIE, individually and in her official capacity as the Director of Personnel for the City of Wilmington; and FRANKLIN AMPADU, M.D., individually and in his official capacity as the Police Surgeon for the City of Wilmington, Defendants. : : : : : : : : : : : : : : : :

Civil Action No.

08-185 JJF

CERTIFICATE OF SERVICE I, Ronald Stoner, hereby attest under penalty of perjury that on this 5th day of June 2008, I caused a copy of Plaintiff Bower's Rule 26(a) Disclosures to be served on the following counsel by electronic filing: Gary Lipkin, Esq. City of Wilmington Law Department Louis L. Reading City/County Bldg. 800 French Street, 9th Floor Wilmington, DE 19801

RONALD STONER, P.A.

/s/ Ronald Stoner Ronald Stoner, Esq., DE 2818 1107 Polly Drummond Plaza Newark, DE 19711 (302) 369-6400 Attorney for Plaintiff