Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00566-JJF Document 9 Filed 11/12/2007 Page1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BARBARA CLEVENGER and PAUL )
CLEVENGER, )
) C.A. No. 07-566
Pl ` `ff ,
V am S g NoN-ARB1rRAr1oN
` ) IURY OF TWELVE DEMANDED
SUSAN M. DONNELLY, M.D., )
LABORATORY CORPORATION OF )
AMERICA, a/k/a LABCORP and LABCORP )
DELAWARE INC., )
)
Defendants. )
DEFENDANT SUSAN M. DONNELLY,M.D.’S INITIAL DISCLOSURES
PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 26ga)(1)
Defendant Susan M. Donnelly, M.D. makes her initial disclosures to Plaintiffs Barbara
Clevenger and Paul Clevenger pursuant to Federal Rule of Civil Procedure 26(a)(1). Defendant
Donnelly submits these initial disclosures based upon information she has acquired to date.
Defendant Donnelly reserves all rights, consistent with Federal Rule of Civil Procedure 26(e), to
modify, amend, and/or supplement the disclosures made herein as additional evidence and
information become available. Defendant Donnelly also reserves the right to object to the
admissibility of any information disclosed herein and reserves any other applicable objections
she may have, including but not limited to objections based on relevance, attomey-client
privilege, work product doctrine, undue burden, or confidentiality.
I. IDENTITIES OF INDIVI])UALS
Pursuant to Rule 26(a)(l)(A), Defendant Donnelly provides the following list of
individuals who may have knowledge of relevant facts. Consistent with Rule 26(e), Defendant
Donnelly reserves the right to amend and/or supplement this list as discovery proceeds in this
action. _

Case 1:07-cv-00566-JJF Document 9 Filed 11/12/2007 Page 2 of 3
ANSWER: Persons identified in applicable medical records. Personnel of Commonwealth
Medical Liability Insurance Company and Morris James, LLP.
II. DOCUlV[ENTS AND THINGS
None known at this time other than the applicable medical records.
Defendant Donnelly reserves the right to amend and/or supplement this production as her
investigation and discovery proceed in this action. By way of further answer, any writings
anticipated to be introduced at trial will be listed as exhibits on the Pre-Trial Stipulation.
III. BASIS FOR DAMAGES
Pursuant to Rule 26(a)(l)(C), Defendant Donnelly states that she does not believe that
any damages are owed to Plaintiffs and reserves the right to respond to any computation of
damages that Plaintiffs may present.
IV. INSURANCE AGREEMENTS
Defendant Donnelly is insured through Commonwealth Medical Liability Insurance
Company, 1115 30* Street, Washington, D.C. 20007. Policy Ntunber: MP61307, Limits of
Liability $1 ,000,000/ $3 ,000,000.
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Case 1:07-cv-00566-JJF Document 9 Filed 11/12/2007 Page 3 of 3
MORRIS JAQES LLP
A _ Richard Galperin( 390)
Amy A. Quinlan (#3021)
500 Delaware Avenue, Suite 1500
P.O. Box 2306
Wilmington, DE 19899-2306
(302) 888-6980
Email: [email protected]
Attorneys for Susan M. Donnelly, M.D.
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