Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00668-LPS Document 17 Filed 06/05/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WHILIAM and MAUREEN ANELLO, I )
Plaintiffs, 5
v. g C.A. N0. 07-668 GMS
INDIAN RIVER SCHOOL DISTRICT g
and SUSAN S. BUNTING, )
Defendants. 5
DEFENDANTS’ INITIAL DISCLOSURES
Pursuant to Rule 26(a)(I) of the Federal Rules of Civil Procedure and Local Rule
16.2, Defendants Indian River School District and Dr. Susan S. Bunting (the "Defendants"),
through their attorneys, submit their Initial Disclosures. Further discovery, investigation, and
research may produce additional relevant facts that may lead to changes in the disclosures set
forth below. These disclosures are complete to the best of the Defendants’ knowledge.
Accordingly, the Defendants reserve the right to amend, supplement or modify these disclosures
as required by Rule 26(e) of the Federal Rules of Civil Procedure.
A. Individuals Likely To Have Discoverable Information That
The Defendants May Use To Support Their Defenses
At present the Defendants have identified the following persons, in addition to
representatives of the Plaintiff, as being reasonably likely to have discoverable information the
I Defendants may use to support their defenses in this matter. The following persons may be
contacted only through the Defendants counsel of record:
The individuals who testified at the Due Process hearings in this matter.

Case 1:07-cv-00668-LPS Document 17 Filed 06/05/2008 Page 2 of 3
B. Description of Documents That Defendants
May Use To Support Their Defenses
At present, the Defendants identify the following categories of documents and
tangible things in their possession, custody or control that they may use to support their defenses:
Evidence entered at the Due Process hearings in this matter.
C. Computation of Damages
The Defendants have not claimed any damages in this matter. However, the
Defendants reserve the right to seek attorney’s fees and costs, and any other relief the Court
deems appropriate, should they prevail in this action.
D. Insurance Coverage
This claim is not covered by the Defendants insurance policies.
MORRIS JAMES LLP
QM
id H. Williams (#616)
[email protected]
James H. McMackin, III (#4284)
[email protected]
500 Delaware Avenue, Suite 1500
Wilmington, DE 19899
Attorneys for the Defendants
Dated: June 5, 2008
JYM/112152-0001/1816534/1 2

Case 1:07-cv-00668-LPS Document 17 Filed 06/05/2008 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WILLIAM and MAUREEN ANELLO, )
)
Plaintiffs, )
)
v. ) C.A. No. 07-668 GMS
)
INDIAN RIVER SCHOOL DISTRICT )
and SUSAN S. BUNTING, )
)
Defendants. )
CERTIFICATE OF ELECTRONIC SERVICE
I hereby certify that on June 5, 2008, I electronically filed the attached
DEF ENDANTS’ INITIAL DISCLOSURES with the Clerk of Court using CM/ECF, and that I
have mailed by United States Postal Service the document to the following non—registered
participant:
William Anello
362 Alba Court
West Grove, PA 19390
Maureen Anello
362 Alba Court
West Grove, PA 19390
%& ll @
id H. Williams (#616)
[email protected]
James H. McMackin, III (#4284)
[email protected]
MORRIS JAMES LLP
500 Delaware Avenue, Suite 1500
P.O. Box 2306
Wilmington, DE 19899
(302) 888-6900/5849
Attomeys for Defendants
mvi/112152-0001/misses/1

Case 1:07-cv-00668-LPS

Document 17

Filed 06/05/2008

Page 1 of 3

Case 1:07-cv-00668-LPS

Document 17

Filed 06/05/2008

Page 2 of 3

Case 1:07-cv-00668-LPS

Document 17

Filed 06/05/2008

Page 3 of 3