Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1 :07—cv—00555-JJF Document 34 Filed 06/19/2008 Page 1 of 2
In the U.S. District Court for the District of Delaware
Xianhua Zhang
Plaintiff Case No. 07-555
vs.
ING Direct Jury Trial Demanded
Defendant
Plaintiff’ s Request for Production of Documents
Addressed to Defendant - Set No. 2
Pursuant to Federal Rules of Civil Procedure 26 and 34, Plaintiff Xianhua Zhang requests that
Defendant ING Direct produce documents hereinafter described and permit Plaintiff to inspect them
and copy them. Plaintiff requests that the documents be made available to Plaintiff at 212 Yorktown
Court, Malvern, PA 19355 within 30 days from date of service hereof. This request is intended to
cover all documents in the possession, custody, and control of any Defendant, Defendant’s agents,
employees, insurance carriers, and attorneys.
NOTE: A response of "will be supplied" or "will supplement" or "discovery is continuing" is
not responsive. You have a duty to provide all items of which you are aware.
Definitions
"Document" or "documents" includes, without limitation, writings and printed matter of any kind
and description, photographs, emails and drawings, notes and records of oral communication, and
recordings (tapes, discs or other) of oral communication. In all cases where originals are not
available, "documents" also means copies of original documents and copies of non-identical copies.
The documents covered by this request are as follows:
1. All documents related to those Defendant’s former employees except Plaintiff with their
contact information including but not limited to home address, email and home phone
number who are discharged by Defendant between 8/1/2004 and 9/1/2006.
2. All documents related to those Defendant’s current or former employees except Plaintiff
with their contact information including but not limited to home address, email and home
phone number who attended that routine company Probation Ending meeting held around
8/10/2005.
3. Copies of Termination! Separation Form for those Defendant’s former employees including
Plaintiff who are discharged by Defendant between 8/ 1/2004 and 9/1/2006.
4. All documents related to Mr. Dan Lu’s annual performance reviews and salary adjustments
from 10/2005 up to now.
5. All documents related to Plaintiffs discharge by Defendant except those sent to PA Bureau
of UC Benefits and Allowances.
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I Xianhua Zhang
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Date: /3 9 U-U-5 I . 4m 4
. U.S. DiST§l2CT GOURT
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Case 1:07—cv—00555-JJF Document 34 Filed 06/19/2008 Page 2 of 2
CERTIFICATE OF SERVICE
I, Xianhua Zhang, hereby certify that true and correct copies of Plaintiff` s Interrogatories
Directed to Defendant Set 2 and Plaintiff’ s Request for Production of Documents
Addressed to Defendant Set 2 have been electronically and timely mailed upon the
following:
David P. Primack [email protected] — Attorney for Defendant
David J. Woolf [email protected] — Attorney for Defendant
Edward N. Yost [email protected] — Attorney for Defendant
A ,u_iW;_;> /”lét../?Q
Xianhua Zhang /
./2 W , I . Plaintiff
Date: E}?//T[ JJ UUE

Case 1:07-cv-00555-JJF

Document 34

Filed 06/19/2008

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Case 1:07-cv-00555-JJF

Document 34

Filed 06/19/2008

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