Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:08-cv-00185-JJF Document 17 Filed 08/26/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DENISE BOWERS,
Plaintiff, C.A. No. 08-185-JJF.
v.
CITY OF WILMINGTON, a municipal JURY TRIAL DEMANDED.
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.
DEFENDANT FRANKLIN AMPADU, M.D.'S RESPONSES TO MANDATORY
DISCOVERY PURSUANT TO RULE 26.2(a) OF THE LOCAL RULES OF CIVIL
PRACTICE AND PROCEDURE OF THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In accordance with Federal Rule of Civil Procedure 26, defendant, Franklin Ampadu,
M.D. makes the following disclosures:
1. The names and last known address of each person reasonably likely to have
information that bears significantly on the claims and defenses, identifying the subjects of the
information.
ANSWER: In addition to those individuals identified by plaintiff, Dr. Ampadu recalls
discussing this matter with Brenda J ames-Roberts of the City of Wilmington Law Department.
2. A general description, including location, of all doctunents, data compilations and
tangible things in the possession, custody or control of that party that are likely to bear
significantly on the claims and defenses.

Case 1:08-cv-00185-JJF Document 17 Filed 08/26/2008 Page 2 of 2
ANSWER: Counsel for this defendant has obtained from the City of Wilmington the letter
dated July 16, 2007 over the signature of Dr. Ampadu and the contract pursuant to which he
provided medical services.
3. A computation of any category of damages claimed by the disclosing party.
ANSWER: Not applicable.
4. The existence and contents of any insurance agreement under which any person or entity
carrying on an insurance business may be liable to satisfy part or all of the judgment that may be
entered in the action, or indemnify or reimburse for payments made to satisfy part or all of the
judgment that may be entered in the action, or indemnify or reimburse for payments made to
satisfy the judgment, making available such agreement for inspection and copying as under
Local Civil Rule 24:
ANSWER: This defendant is insured by Preferred Physicians Insurance Company, Omaha,
Nebraska, with liability limits of $l,000,000.00. This company has informed Dr. Ampadu that
while it is providing him with a legal defense in this matter, it has reserved its right to contest the
applicability of its coverage to these claims.
PRICKETT, JONES & ELLIOTT, P.A.
\/\/K ifi
BY: MASON E. TURNER, JR., No. 661
1310 KING STREET
P.O. BOX 1328
WILMINGTON, DE 19899
(302) 888-6508
ATTORNEY FOR DEFENDANT
FRANKLIN AMPADU, M.D.
Dated: Augusfgé, 2008.

Case 1:08-cv-00185-JJF

Document 17

Filed 08/26/2008

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Case 1:08-cv-00185-JJF

Document 17

Filed 08/26/2008

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