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EXHIBIT A
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Edward N. Yost 215-988-1122 edvcard.y~st@ dbr.com
Law Offices One Logan Square 18TH and Cherry Streets Philadelphia, PA
19103-6996
Apfil18,2008 VIA ELECTRONIC MAIL AND OVERNIGHT DELIVERY Xianhua Zhang 212 Yorktown Court Malvern, PA 19355 RE: Zhang v. ]NG Direct, No. 07-555 (Dist. Del.)
215-988-27oo phone
215-988-a757 fax
www.drinkerbiddle.com
CALIFORNIA DELAWARE ILLINOIS NEW JERSEY NEW YORK PENNSYLVANIA WASHINGTON DC "~VISCONSIH
Dear Mr. Zhang: I write to address several open discovery issues, including the following: (1) We sent you a HIPAA release form on April 3, 2008 and asked you to complete a separate form for each physician you list in response to our interrogatories and return each form to us. David Woolf reminded you of our need for the completed forms on April 10, 2008 and you indicated in your discovery responses that you would be providing them. As of today's date, you have not yet provided us with these forms. Please send us these completed forms as soon as possible so that we may obtain your medical records and explore the claims you make in the Complaint. Incidentally, if you are currently working at the CDI office located at 1717 Arch Street in Philadelphia, we can send someone to your office to pick up the HIPAA authorization forms (our office is less than a block away), which will ensure confidentiality. We have not yet received your initial disclosures as required by Federal Rule of Civil Procedure 26(a)(1). Please provide this information as soon as possible. Enclosed is a notice of your deposition. We are able to take your deposition in our Philadelphia office on May 7, 2008 or May 8, 2008. Please let me know as soon as possible whether you are available to be deposed on either of these dates. In response to interrogatory number 3, you identify CDI as your current employer but provide almost no information about that employment. We plan to subpoena your employment records from CDI under Federal Rule of Civil Procedure 45. Please consider this letter as our notification to you that we will be sending out that subpoena shortly.
(2)
(3)
(4)
Established 1849
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DrinkerBiddleS :/a
Xianhua Zhang April 18, 2008 Page 2
(5)
You refer to "evidences in the Complaint" in several instances in response to document requests or interrogatories. Please define for us what "evidences in the Complaint" means and provide any documents that constitute such evidence. Your responses to our interrogatories and document requests are deficient in several respects. These deficiencies are detailed for you below. Please provide to me the information and documents requested below within 10 calendar days of the date of this letter.
(6)
In response to interrogatory number 2, which asks that you "describe in detail the efforts you made to obtain work or employment," you simply state, "I did work hard to apply for new jobs." This response is deficient. Please supplement this response to include the name of the employers you contacted, the date you contacted them, the terms and conditions of the prospective employment and the disposition and reason(s) for the disposition of your application. You refuse to respond to Interrogatory number 5, which asks whether you have ever been a party to civil or criminal litigation and asks that you state the full name of each lawsuit to which you have been a party, the docket number and the court in which it was filed. The basis for your refusal is that the interrogatory "exceeds the scope of permissible discovery related to this case." The type of information requested in interrogatory number 5, however, is routinely both requested and provided in civil cases such as your case. Moreover, the federal rules of evidence specifically provide that certain prior criminal convictions are admissible at trial under certain circumstances. See Fed. R. Evid. 608. You provide us with the names of twelve (12) medical providers in response to interrogatory number 10. The interrogatory, however, requests that you list the medical providers whom you have sought treatment or consulted with for any harm or damage alleged in the Complaint. Please confirm to us that are claiming that these medical providers treated you for harm or damage you allegedly suffered as a result of the actions of ING Bank. In response to interrogatory numbers 16 and 17, you object to responding at all on the basis of the attorney-client privilege. It is our understanding that you are proceeding in this case without the aid of legal counsel. If you are represented by, or are consulting with legal counsel in this case, we do not want to know the substance of any conversations you had with this person. We do need to know, however, who that person is and the nature of their involvement in this case.
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Xianhua Zhang April 18, 2008 Page 3
As with your responses to our interrogatories, several of your responses to our document requests are deficient. Specifically, you have failed to provide any documentation whatsoever in response to document request number 10, which requests that you provide us with documentation of all of the income you received since August 16, 2005. This documentation is absolutely essential to litigate this case. Without it, we are cannot assess your alleged damages claim. Please send us all employment agreements, independent contractor agreements, pay stubs, federal state and local income tax forms, any W-2s you have, unemployment benefit documents, worker's compensation documents and short or long-term disability documents or other insurance payment documents that you have received on or after August 16, 2005. You also have not provided any documents in response to document requests 11 or 12, which request'all documents relating to your attempts to obtain employment and all documents with regard to any employment you have obtained since August 16, 2005. These requests are also directly related to any alleged damages you claim ING Bank owes you. Accordingly, please send us all employment applications that you submitted, resumes that you submitted, correspondence that you sent or received, notes that you kept, offers of employment that you received, and/or refusals of employment that you received as of August 16, 2005. In response to document request number 17, you list your damages without providing any supporting documentation. As explained, above, this documentation is required to litigate this case. Thus, please send us any and all documents that evidence, refer or relate to any harm or damage you believe you have suffered as a result of the conduct of ING Bank, including alleged monetary, emotional or other harm. Your objection to requests 21, 22 and 23, which requests that you provide the documents you sent to the U.S. Equal Employment Opportunity Commission regarding this case, the documents you took with you from ING Bank after your employment concluded, and documents that describe any civil or criminal litigation in which you were involved, is unfounded. These document requests are not overly broad or unreasonable as you claim. They are directly related to your claims and are necessary to litigate this case. Please provide this information as requested.
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Xianhua Zhang April 18, 2008 Page 4 Thank you for your anticipated cooperation in providing to us the necessary information and documentation described above. If you would like to discuss these issues, please contact me at 215-988-1122.
Since.rely yours,
Edward N. Yost ENY cc: David J. Woolf, Esquire
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
XIANHUA ZHANG Plaintiff, Case No. 07-555 (JJF)
ING DIRECT Defendant.
NOTICE OF PLAINTIFF'S DEPOSITION Xianhua Zhang, prose 212 Yorktown Court Malvem, PA 19355 PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30, Defendant ING Direct, by its undersigned counsel, will take the deposition of PlaintiffXianhua Zhang before a person duly authorized to administer oaths, at the offices of Drinker Biddle & Reath LLP, 1100 N. Market Street, Wilmington, DE ¯19801-1254, beginning at 10:00 a.m., on May 7, 2008, and continuing until completed. The deposition will be recorded stenographically. Dated: April 18, 2008 David P. Primack (I.D. No. 4449) DRINKER BIDDLE & REATH LLP ¯ 1100 N. Market Street Wilmington, DE 19801-1254 (302) 467-4220 OF COUNSEL: David J. Woolf (admitted pro hac vice) Edward N. Yost (admitted pro hac vice) DRINKER BIDDLE & REATH LLP One Logan Square 18t~ & Cherry Streets Philadelphia, PA 19103 (215) 988-2700 Attorneys for Defendant 1NG Bank, fsb
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CERTIFICATE OF SERVICE I, David P. Primack, hereby certify that, on this date, I caused a true and correct copy of the foregoing Notice of Plaintiff's Deposition to be served on the plaintiff by electronic and firstclass U.S. mail, postage prepaid, at the following address: Xianhua Zhang 212 Yorktown Court Malvem, PA 19355
Dated: April 18, 2008 David P. Primack
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EXHIBIT B
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Yost, Edward N. From: Peter Zhang [[email protected]] Tuesday, April 22, 2008 9:57 PM Sent: To: Yost, Edward N. Subject: Re: Zhang v. ING Direct Mr. Yost, There is no issue for me to do deposition. But your office is too far from my home. In addition, I am paid hourly. That means I will not be paid for those hours for depostion and on the ways. So I suggest to take depsoition at my home. I work from home. So there should no issues to do deposition at my home. I still am reviewing your letter. You ask me to provide further info within 10 days. Please let me know that you set this time based on which Fedreal Rule of Civil Procedures.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
Disclaimer Required by IRS Rules of Practice: Any discussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or
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disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply [email protected] and delete the message. Thank you very much.
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EXHIBIT C
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Yost, Edward N. From: Sent: To: Cc: Peter Zhang [[email protected]] Saturday, April 26, 2008 10:49 PM Yost, Edward N. Woolf, David J. (Philadelphia Partner)
Subject: Re: Zhang v. ING Direct Mr. Yost,
I do not think it is not formal to do deposition at my home. If you do not like it, I can do telephone deposition.
Thanks,
Peter Zhang
..... Original Message .... From: "Yost, Edward N."
6/12/2008
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Mr. Yost, There is no issue for me to do deposition. But your office is too far from my home. In addition, I am paid hourly. That means I will not be paid for those hours for depostion and on the ways. So I suggest to take depsoition at my home. I work from home. So there should no issues to do deposition at my home. I still am reviewing your letter. You ask me to provide further info within 10 days. Please let me know that you set this time based on which Fedreal Rule of Civil Procedures.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
Disclaimer Required by IRS Rules of Practice: Any discussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply [email protected] and delete the message. Thank you very much.
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EXHIBIT D
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Yost, Edward N. From: Sent: Peter Zhang [[email protected]] Tuesday, April 29, 2008 10:48 PM To: Yost, Edward N. Cc: Woolf, David J. (Philadelphia Partner) Subject: Re: Zhang v. ING Direct Mr. Yost, Will ING Direct or your firm reimbuse me my time away from job, parking and milage for the deposition at your office as required by law?
Peter Zhang
..... Original Message .... From: "Yost, Edward N."
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I do not think it is not formal to do deposition at my home. If you do not like it, I can do telephone deposition.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
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Peter Zhang ..... Original Message .... From: "Yost, Edward N."
Disclaimer Required by IRS Rules of Practice: Any discussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply [email protected] and delete the message. Thank you very much.
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EXHIBIT E
Message Case 1:07-cv-00555-JJF
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Yost, Edward N. From: Sent:
To: Cc: Yost, Edward N. Monday, May 05, 2008 9:18 AM 'Peter Zhang' Woolf, David J. (Philadelphia Partner)
Subject: RE: Zhang v. ING Direct Mr. Zhang, ING Bank has no obligation whatsoever to reimburse you for anything regarding your deposition. You have brought this suit against ING Bank. As a Plaintiff, you have an obligation to make yourself available to be deposed in a reasonable fashion. We have been more than accommodating to you in offering you three different locations to take your deposition, one of which is only 7.4 miles from your home. You, however, have failed to respond to ING Bank's April 15, 2008 letter outlining the deficiencies in your responses to our discovery requests and you have failed to respond to our repeated requests to pick a location to hold your deposition. Due to your refusal to comply with the discovery process, we will not be able to take your deposition on May 7 or May 8 as initially proposed. Thus, please provide us with several dates when you are available to be deposed over the next few weeks. If you do not respond to our April 15, 2008 letter and fail to choose a location to be deposed, we will seek the intervention of the Court.
..... Original Message ..... From: Peter Zhang [mailto:[email protected]] Sent: Tuesday, April 29, 2008 10:48 PM To; Yost, Edward N. Cc: Woolf, David J. (Philadelphia Partner) Subject: Re: Zhang v. ING Direct
Mr. Yost, Will ING Direct or your firm reimbuse me my time away from job, parking and milage for the deposition at your office as required by law? Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
6/12/2008
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Mr. Zhang: While we again appreciate your offer to conduct your deposition in your home, we do not feel that your home is an appropriate location. We also feel that a telephone deposition is not appropriate given that you live only 7.4 miles from our Berwyn, PA office. In order to make this process as convenient for you as possible, we are willing to take your deposition in our Berwyn, PA office or our Philadelphia, PA office or our Wilmington, DE office. If you refuse all of these options, we will be forced to raise the issue with Judge Farnan. Please let me know as soon as possible whether you are willing to come to any of the above offices so that we may take your deposition. ..... Original Message ..... From: Peter Zhang [mailto:[email protected]] Sent: Saturday, April 26, 2008 10:49 PM To: Yost, Edward N. C¢: Woolf, David J. (Philadelphia Partner) Subject:: Re: Zhang v. ING Direct Mr. Yost,
I do not think it is not formal to do deposition at my home. If you do not like it, I can do telephone deposition.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
6/12/2008
Message Case 1:07-cv-00555-JJF
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discovery requests were due. We allowed you 10 extra days to provide us the information requested in our discovery as a courtesy. Please provide the information requested in the letter within the timeframe described. ..... Original Message ..... From: Peter Zhang [mailto:[email protected]] ~ent-" Tuesday, April 22, 2008 9:57 PM To-" Yost, Edward N. Subject-" Re: Zhang v. ING Direct Mr. Yost, There is no issue for me to do deposition. But your office is too far from my home. In addition, I am paid hourly. That means I will not be paid for those hours for depostion and on the ways. So I suggest to take depsoition at my home. I work from home. So there should no issues to do deposition at my home. I still am reviewing your letter. You ask me to provide further info within 10 days. Please let me know that you set this time based on which Fedreal Rule of Civil Procedures.
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
Disclaimer Required by IRS Rules of Practice: Any dlscussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed
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under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply [email protected] and delete the message. Thank you very much.
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EXHIBIT F
Case 1:07-cv-00555-JJF Yost, Edward N.
From: Sent: To: Cc: Subject: Attachments:
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Yost, Edward N. Wednesday, May 07, 2008 5:55 PM 'Peter Zhang' Woolf, David J. (Philadelphia Partner) Zhang v. ING - Confidentiality Agreement Ij5d01_.DOC
ljSdOl_.DOC (39 KB)
r. Zhang,
Attached is a confidentiality agreement and protective order regarding materials to be exchanged by the parties during the discovery process in the lawsuit you have brought against ING Bank. Once you have reviewed and signed the agreement, please return it to my attention. When we receive the signed agreement, we will produce to you documents related to Dan Lu's performance evaluations as you have requested. Also, we sent you documents responsive to your discovery requests yesterday via ovemight mail. Thus, your continued refusal to respond fully to our discovery requests is absolutely without basis. Thus, we demand that you immediately provide us with proper responses to our discovery requests as outlined in my previous letter to you. Also, we propose to take your deposition on Monday, June 9, 2008 at 10:00 a.m. in either our Berwyn, Philadelphia or Delaware offices. Please inform me immediately which office at which you wish to appear.
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EXHIBIT G
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Yost, Edward N. Yost, Edward N. Tuesday, May 13, 2008 10:49 AM To: 'Peter Zhang' Woolf, David J. (Philadelphia Partner) Cc: Subject: RE: Zhang v. ING Bank - Deposition Mr. Zhang, Is there any reason you cannot firmly commit to June 12, 2008? You may not be aware of this, but it is discourteous and improper to leave yourself a way to opt out of your deposition with only a few days notice. Several people are going to rearrange their schedules to attend your deposition including Mr. Woolf, myself, an ING representative and a court reporter. Thus, absent any emergency situation, we expect that you will be at our office in Berwyn on June 12, 2008 at 10:D0 a.m. We are not willing to start the deposition at 11:00 a.m. because we might not be able to finish your deposition on June 12, 2008, which will require us to recall you on another date and pose another inconvenience for all concerned. Moreover, the issue you raise regarding "readable" documents is irrelevant regarding whether we are authorized to take your deposition. We are entitled to take your deposition under the Rules without your continued efforts to place contingencies on whether or not you will arrive. In any event, we will work with you to provide you with "readable" documents although the documents we produced to you were legible when they left our office. We expect to see you on June 12, 2008 at 10:00 a.m. absent any emergency situation. .....Original Message ..... From: Peter Zhang [mailto:[email protected]] Sent: Monday, May 12, 2008 11:55 PM To: Yost, Edward N. Cc: Woolf, David J. (Philadelphia Partner) Subject: Re: Zhang v. ING Bank - Deposition Mr. Yost, I basically agree to go to your offices in Berwyn at 11 am on June 12, 2008 to take deposition. But you need to provide those missing or readable documents first listed in my previous email. I will do my best to take deposition that date. If I cannot, I will let you know at least couple of days earlier. Thanks, From: Sent:
Peter Zhang
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..... Original Message .... From: "Yost, Edward N."
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Yost, Edward N. From: Sent:
To: Cc: Yost, Edward N. Monday, May 19, 2008 3:56 PM 'Peter Zhang' Woolf, David J. (Philadelphia Partner)
Subject: RE: Zhang v. ING - Confidentiality Agreement Mr. Zhang, All of the documents produced to you are "readable." Nonetheless, my assistant has "blown-up" several documents to make them easier for you to read. To ensure that the documents remain as clear as possible, I am sending them to you via regular mail. If you still cannot read these documents after they have been blown-up, I suggest you obtain a magnifying glass to assist your eyes when reviewing the documents. As for your question below, we have produced to you the documents in our possession, custody or control that are responsive to your document requests. Thus, no documents are "missing" as you allege.
..... Original Message ..... From= Peter Zhang [mailto:peterzhang9999@yahoo~com] Sent= Thursday, May 15, 2008 8:35 PM To; Yost, Edward N. (::¢-" Woolf, David J. (Philadelphia Partner) Subject-" Re: Zhang v. ING - Confidentiality Agreement
Any updates?
Thanks,
Peter Zhang ..... Original Message .... From: Peter Zhang
I attach one page as example.
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Those unreable documents are from ING-0002 to ING-0013, and ING-0174 is just barely readable. Please check and resend readable documents asap. What do you mean for the following statements: As for any documents you feel are "missing", I represent to you that, after a reasonable search, these documents were not found. Please clarify asap.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
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because they are not readable. Please provide readable documents asap. Request 16: No documents. Please provide readable documents asap. Request 17: No documents. Please provide readable documents asap. Request 18: Missing one email. Please provide readable documents asap. Request 22: No documents. Please provide readable documents asap. Requests 23 & 28: Can not determine whether correct documents are provided or not because they are not readable. Please provide readable documents asap. Please specify when I will get those documents.
Thanks,
Peter Zhang ..... Original Message .... From: "Yost, Edward N."
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Disclaimer Required by IRS Rules of Practice: Any discussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply [email protected] and delete the message. Thank you very much.
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EXHIBIT I
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Yost, Edward N. From: Sent: To: Cc: Peter Zhang [[email protected]] Tuesday, June 03, 2008 11:29 PM Yost, Edward N.; peter
Woolf, David J. (Philadelphia Partner); Primack, David P. Zhang v. ING Bank -- Plaintiffs Reply to Defendant's Letter on 4/18/2008 for Issues Related to Subject: Discoveries Including Interrogatories and Request for Production of Documents Attachments: jobApp.doc; res05.doc; verif01.pdf Dear Mr. Attorneys: Since the start of discovery process, I have strictly followed the rules to fulfill my obligations on time. However, Defendant has done a very poor job to act the same way. For example I have still not got some documents that were promised by you on 4/28/2008 after over one month waiting. See my email sent to you on 5/27/2008 for details. Nevertheless I still answer your issues listed in 4/18/2008 letter to show spirit of fair play and my willingness to fulfill my obligations in this case. Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents Issue # 1: See my email sent to you on 4/24/2008. It is said in the form that a photocopy 'shall be effective as an original'. So just make 12 copies and fill those health care providers' names and send with subpoenas. In addition, you have already sent me copies of those subpoenas that are supposed to have been sent to those 12 health care providers. Why do you keep bothering me for this??? Issue # 2: I have replied to your discovery requests of Interrogatories and Request for Production of Documents Set One within timeline set by the law. Why do you keep bothering me for this??? Issue # 3: Since Defendant has not followed the rules to fulfill obligations on time during discovery process, there is no obligation for me to take the deposition defined by Defendant. Issue # 4: No objection. Issue # 5: All facts stated in Complaint are evidences. Issue # 6: Answers as the followings: Interrogatory # 2: Plaintiff still objects this interrogatory on the ground that as h exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'the date of each such effort,' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, it only took Plaintiff about 3.5 months to get a new job that is a very short time based on the job situation at that time mainly because of Plaintiff's hard effort. Nevertheless, Plaintiff here is willing to provide more information for my job searching efforts. I only used job web resources to find and apply the new job. Those web sites are www.jobcircle.com, www.dice.com, www.monster.com and www. CareerBuilder.com. My resume and emails sent to potential employers are attached. I even drove to DC area to get an interview with
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Fannie Mae. All these are proved evidences for my hard efforts to get the new job. Interrogatory # 5: Federal Rules of Evidence 608. Evidence of Character and Conduct of Witness has nothing to do with your claims. Nevertheless, I have never been involved in any criminal litigations. Even though I do have a civil case of personal injury pending that I sue the man who hit me from behind during an auto accident 1/24/03, that case has nothing to do with this one. Interrogatory # 10: N/A. Interrogatory # 16: N/A. Interrogatory # 17: N/A. Document Request # 10: Plaintiff still objects this interrogatory on the ground that as it exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'pay stubs' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, Plaintiff only has two sources of incomes since 8/2005. One is unemployment pay and the other is wage income as Consultant for CDI since end of 11/05 up to now. Since Defendant has already subpoenaed CDI, there is no base to require Plaintiff to repeat the same job. BTW, Plaintiff is entitled to get an exact copy of all documents from subpoena to CDI as required by law. In addition, Plaintiff does not claim any wage loss damage against Defendant for the time between 11/2005 and now at this point. Therefore I am not required by law to provide my income information for this period of time. Document Request # 11: See answers to Interrogatory # 2, attached my resume as of 2005 and screenshots for all emails related to job search efforts. Document Request # 12: See answers to Document Request # 10. Document Request # 17: I have answered this request in details with evidences presented in responses to Defendant's discovery requests such as Job Offer Letter and Employee Handbook (2005). In addition, document ING-0174 and all documents from subpoena to CDI are also severed as supporting documentation. What documents of legal evidences permitted by law do you want? Document Request # 21: Plaintiff still objects this request because there are no legal connections between the documents in Charge filed to EEOC and this case. Document Request # 22: Plaintiff still objects this request because it is pure allegation. It is Defendant, not me that takes others' belongings. Even I wanted to follow Defendant's example after I was illegally discharged, I could not because I had lost the control of my personal belongings and was at the mercy of Defendant to get only part of them back. Document Request # 23: See answers to Interrogatory # 5.
Xianhua Zhang Plaintiff Date: 6/3/2008
6/12/2008
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Document 31-10
Filed 06/16/2008
Page Page 4 of 4 3 of 3
BTW, I forgot to attach Verification for 'Plaintiff's Answers and Objections to Defendant's Interrogatories Directed to Plaintiff- Set No. 1' last time. It is attached this time. In addition, I sent you two emails with attachments for some discovery issues on 5/27/2008. I am sure you have got them. But I have not got any responses for them from you yet. Please follow the rules set by law to respond them at your earliest convenience.
Sincerely, Xianhua Zhang
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-11
Filed 06/16/2008
Page 1 of 4
EXHIBIT J
Case 1:07-cv-00555-JJF
Document 31-11
Filed 06/16/2008
Page Page 2 of 4 1 of 3
Yost, Edward N. From: Sent: To: Yost, Edward N. Wednesday, June 04, 2008 10:13 AM 'Peter Zhang' Woolf, David J. (Philadelphia Partner); Primack. David P.
Cc: Subject: RE: Zhang v. ING Bank-- Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents File: -1
Mr. Zhang: In issue #3 below, you seem to suggest that you will not be attending your deposition scheduled for June 12, 2008. Please confirm for me ASAP whether you will be attending your deposition on June 12, 2008. We have scheduled a court reporter, reserved a conference room and cleared our schedules for your deposition. We expect that, as a point of common courtesy, you will inform us immediately whether or not you will appear at your deposition as agreed. As for the remaining discovery "issues" you have recently sent us, we plan on dealing with them yet again shortly. Nonetheless, these issues are irrelevant regarding whether you have an obligation to make yourself available to be deposed.
From: Peter Zhang [mailto:[email protected]] Sent: Tuesday, June 03, 2008 11:29 PM To; Yost, Edward N.; peter Cc; Woolf, David J. (Philadelphia Partner); Primack, David P. Subject: Zhang v. ING Bank -- Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents Dear Mr. Attorneys: Since the start of discovery process, I have strictly followed the rules to fulfill my obligations on time. However, Defendant has done a very poor job to act the same way. For example I have still not got some documents that were promised by you on 4/28/2008 after over one month waiting. See my email sent to you on 5/27/2008 for details. Nevertheless I still answer your issues listed in 4/18/2008 letter to show spirit of fair play and my willingness to fulfill my obligations in this case. Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents Issue # 1: See my email sent to you on 4/24/2008. It is said in the form that a photocopy 'shall be effective as an original'. So just make 12 copies and fill those health care providers' names and send with subpoenas. In addition, you have already sent me copies of those subpoenas that are supposed to have been sent to those 12 health care providers. Why do you keep bothering me for this??? Issue # 2: I have replied to your discovery requests of Interrogatories and Request for Production of
6/12/2008
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Document 31-11
Filed 06/16/2008
Page Page 3 of 4 2 of 3
Documents Set One within timeline set by the law. Why do you keep bothering me for this??? Issue # 3: Since Defendant has not followed the rules to fulfill obligations on time during discovery process, there is no obligation for me to take the deposition defined by Defendant. Issue # 4: No objection. Issue # 5: All facts stated in Complaint are evidences. Issue # 6: Answers as the followings: Interrogatory # 2: Plaintiff still objects this interrogatory on the ground that as it exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'the date of each such effort,' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, it only took Plaintiff about 3.5 months to get a new job that is a very short time based on the job situation at that time mainly because of Plaintiff's hard effort. Nevertheless, Plaintiff here is willing to provide more information for my job searching efforts. I only used job web resources to find and apply the new job. Those web sites are www.jobcircle.com, www.dice.com, www.monster.com and www. CareerBuilder.com. My resume and emails sent to potential employers are attached. I even drove to DC area to get an interview with Fannie Mae. All these are proved evidences for my hard efforts to get the new job. Interrogatory # 5: Federal Rules of Evidence 608. Evidence of Character and Conduct of Witness has nothing to do with your claims. Nevertheless, I have never been involved in any criminal litigations. Even though I do have a civil case of personal injury pending that I sue the man who hit me from behind during an auto accident 1/24/03, that case has nothing to do with this one. Interrogatory # 10: N/A. Interrogatory # 16: N/A. Interrogatory # 17: N/A. Document Request # 10: Plaintiff still objects this interrogatory on the ground that as it exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'pay stubs' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, Plaintiff only has two sources of incomes since 8/2005. One is unemployment pay and the other is wage income as Consultant for CDI since end of 11/05 up to now. Since Defendant has already subpoenaed CDI, there is no base to require Plaintiff to repeat the same job. BTW, Plaintiff is entitled to get an exact copy of all documents from subpoena to CDI as required by law. In addition, Plaintiff does not claim any wage loss damage against Defendant for the time between 11/2005 and now at this point. Therefore I am not required by law to provide my income information for this period of time. Document Request # 11: See answers to Interrogatory # 2, attached my resume as of 2005 and screenshots for all emails related to job search efforts. Document Request # 12: See answers to Document Request # 10. Document Request # 17: I have answered this request in details with evidences presented in responses
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Page Page 4 of 4 3 of 3
to Defendant's discovery requests such as Job Offer Letter and Employee Handbook (2005). In addition, document ING-0174 and all documents from subpoena to CDI are also severed as supporting documentation. What documents of legal evidences permitted by law do you want? Document Request # 21: Plaintiff still objects this request because there are no legal connections between the documents in Charge filed to EEOC and this case. Document Request # 22: Plaintiff still objects this request because it is pure allegation. It is Defendant, not me that takes others' belongings. Even I wanted to follow Defendant's example after I was illegally discharged, I could not because I had lost the control of my personal belongings and was at the mercy of Defendant to get only part of them back. Document Request # 23: See answers to Interrogatory # 5.
Xianhua Zhang Plaintiff Date: 6/3/2008 BTW, I forgot to attach Verification for 'Plaintiff's Answers and Objections to Defendant's Interrogatories Directed to Plaintiff- Set No. 1' last time. It is attached this time. In addition, I sent you two emails with attachments for some discovery issues on 5/27/2008. I am sure you have got them. But I have not got any responses for them from you yet. Please follow the rules set by law to respond them at your earliest convenience. Sincerely,
Xianhua Zhang
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-12
Filed 06/16/2008
Page 1 of 6
EXHIBIT K
Case 1:07-cv-00555-JJF
Document 31-12
Filed 06/16/2008
Page Page 2 of 6 1 of 5
Yost, Edward N.
From: Sent: To: Cc: Peter Zhang [[email protected]] Monday, June 09, 2008 9:55 PM Woolf, David J. (Philadelphia Partner) Yost, Edward N.
Subject: Re: Zhang v. ING Bank -- Plaintiffs Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents Mr. Attorneys:
Discovery process is an obligatios to the two parties. I am not against taking depsotion, but not now because I am still waiting the satisfactory responses to my emails sent on 5/27/2008. I will take deposition only after Dfendant fulfills their obligations in the discovery process.
Peter Zhang ..... Original Message .... From: "Woolf, David J. (Philadelphia Partner)"
Mr. Zhang, This email also came back as undeliverable so I am resending. David Woolf
Disclaimer Required by IRS Rules of Practice: Any discussion of tax matters contained herein is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties that may be imposed under Federal tax laws. This message contains information which may be confidential and privileged. Unless you are the intended addressee (or authorized to receive for the intended addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender at Drinker Biddle & Reath LLP by reply ~dbr.com and delete the message. Thank you very much.
..... Original Message ..... From: Woolf, David J. (Philadelphia Partner) To: 'Peter Zhang'
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-12
Filed 06/16/2008
Page Page 3 of 6 2 of 5
Cc: Yost, Edward N. Sent: Mon Jun 09 15:52:13 2008 Subject: RE: Zhang v. ING Bank -- Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents Mr. Zhang, Are you attending your deposition this Thursday in Berwyn? We need to know ASAP. Thank you. David Woolf David J. Woolf] DrinkerBiddle ] One Logan Square ] Philadelphia, PA 19103 I t:215.988.2614 1 f:215.988.2757 ] [email protected] I www.drinkerbiddle.com
From: Yost, Edward N. Sent: Wednesday, June 04, 2008 10:13 AM To: 'Peter Zhang' Cc: Woolf, David J. (Philadelphia Parmer); Primack, David P. Subject: RE: Zhang v. ING Bank -- Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents
Mr. Zhang: In issue #3 below, you seem to suggest that you will not be attending your deposition scheduled for June 12, 2008. Please confirm for me ASAP whether you will be attending your deposition on June 12, 2008. We have scheduled a court reporter, reserved a conference room and cleared our schedules for your deposition. We expect that, as a point of common courtesy, you will inform us immediately whether or not you will appear at your deposition as agreed. As for the remaining discovery "issues" you have recently sent us, we plan on dealing with them yet again shortly. Nonetheless, these issues are irrelevant regarding whether you have an obligation to make yourself available to be deposed.
From: Peter Zhang [mailto:[email protected]] Sent: Tuesday, June 03, 2008 11:29 PM To: Yost, Edward N.; peter Cc: Woolf, David J. (Philadelphia Partner); Primack, David P. Subject: Zhang v. ING Bank -- Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents
Dear Mr. Attorneys:
Since the start of discovery process, I have strictly followed the rules to fulfill my obligations on time. However, Defendant has done a very poor job to act the same way. For example I have still not got some documents that were promised by you on 4/28/2008 after over one month,waiting. See my email sent to you on 5/27/2008 for details.
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-12
Filed 06/16/2008
Page Page 4 of 6 3 of 5
Nevertheless I still answer your issues listed in 4/18/2008 letter to show spirit of fair play and my willingness to fulfill my obligations in this case.
Plaintiff's Reply to Defendant's Letter on 4/18/2008 for Issues Related to Discoveries Including Interrogatories and Request for Production of Documents
Issue # 1: See my email sent to you on 4/24/2008. It is said in the form that a photocopy 'shall be effective as an original'. So just make 12 copies and fill those health care providers' names and send with subpoenas. In addition, you have akeady sent me copies of those subpoenas that are supposed to have been sent to those 12 health care providers. Why do you keep bothering me for this???
Issue # 2: I have replied to your discovery requests of Interrogatories and Request for Production of Documents Set One within timeline set by the law. Why do you keep bothering me for this???
Issue # 3: Since Defendant has not followed the rules to fulfill obligations on time during discovery process, there is no obligation for me to take the deposition def'med by Defendant.
Issue # 4: No objection.
Issue # 5: All facts stated in Complaint are evidences.
Issue # 6: Answers as the followings:
Interrogatory # 2: Plaintiff still objects this interrogatory on the ground that as it exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'the date of each such effort,' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, it only took Plaintiff about 3.5 months to get a new job that is a very short time based on the job situation at that time mainly because of Plaintiff's hard effort. Nevertheless, Plaintiff here is willing to provide more information for my job searching efforts. I only used job web resources to fred and apply the new job. Those web sites are www.jobcircle.com
Interrogatory # 5: Federal Rules of Evidence 608. Evidence of Character and Conduct of Witness has nothing to do with your claims. Nevertheless, I have never been involved in any criminal litigations. Even though I do have a civil case of personal injury pending that I sue the man who hit me from behind during an auto accident 1/24/03, that case has nothing to do with this one.
Interrogatory # 10: N/A.
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Page Page 5 of 6 4 of 5
Interrogatory # 16: N/A.
Interrogatory # 17: N/A.
Document Request # 10: Plaintiff still objects this interrogatory on the ground that as it exceeds the scope of permissible discovery related to this case as being broad, unreasonable, burdensome and unduly oppressive. For example, it requires 'pay stubs' etc. Such detailed demands are clearly broad, unreasonable, burdensome and unduly oppressive to the Plaintiff and has nothing to do with the case. Subject to and without waiving this or any other applicable objections, Plaintiff only has two sources of incomes since 8/2005. One is unemployment pay and the other is wage income as Consultant for CDI since end of 11/05 up to now. Since Defendant has already subpoenaed CDI, there is no base to require Plaintiffto repeat the same job. BTW, Plaintiff is entitled to get an exact copy of all documents from subpoena to CDI as required by law. In addition, Plaintiff does not claim any wage loss damage against Defendant for the time between 11/2005 and now at this point. Therefore I am not required by law to provide my income information for this period of time.
Document Request # 11: See answers to Interrogatory # 2, attached my resume as of 2005 and screenshots for all emails related to job search efforts.
Document Request # 12: See answers to Document Request # 10.
Document Request # 17: I have answered this request in details with evidences presented in responses to Defendant's discovery requests such as Job Offer Letter and Employee Handbook (2005). In addition, document ING-0174 and all documents from subpoena to CDI are also severed as supporting documentation. What documents of legal evidences permitted by law do you want?
Document Request # 21: Plaintiff still objects this request because there are no legal connections between the documents in Charge filed to EEOC and this case.
Document Request # 22: Plaintiff still objects this request because it is pure allegation. It is Defendant, not me that takes others' belongings. Even I wanted to follow Defendant's example after I was illegally discharged, I could not because I had lost the control of my personal belongings and was at the mercy of Defendant to get only part of them back.
Document Request # 23: See answers to Interrogatory # 5.
&n bsp;
Xianhua Zhang
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-12
Filed 06/16/2008
Page Page 6 of 6 5 of 5
Plaintiff Date: 6/3/2008
BTW, I forgot to attach Verification for 'Plaintiff's Answers and Objections to Defendant's Interrogatories Directed to Plaintiff- Set No. 1' last time. It is attached this time.
In addition, I sent you two emails with attachments for some discovery issues on 5/27/2008. I am sure you have got them. But I have not got any responses for them from you yet. Please follow the rules set by law to respond them at your earliest convenience.
Sincerely,
Xianhua Zhang
6/12/2008
Case 1:07-cv-00555-JJF
Document 31-13
Filed 06/16/2008
Page 1 of 11
EXHIBIT L
Case 1:07-cv-00555-JJF
Document 31-13
Filed 06/16/2008
Page 2 of 11
DrinkerBiddle&
Law OJ~ces One Logan Square 18TH and Cherry Streets Philadelphia, PA
~91o3-6996 215-988-27OO phone 215-988-2757 fax
Edward N. Yost Associate 215-988-1122 Direct 215-988-2757 Fax [email protected]
June 11, 2008 VIA FEDERAL EXPRESS Xianhua Zhang 212 Yorktown Court Malvem, PA 19355 Re: Zhang v. ING Direct Dear Mr. Zhang: In the email you sent to my colleague David Woolf and I dated June 9, 2008, you cancelled your deposition scheduled for June 12, 2008. In that email you claim that you are unwilling to be deposed because you are "still waiting the satisfactory responses to [your] emails sent on 5/27/2008." Your reason for cancelling your deposition is both unreasonable and unsupported by the Federal Rules of Civil Procedure. Nonetheless, in an effort to yet again address your claimed discovery issues, we sent you the enclosed letter and its attachments yesterday afternoon via regular mail and twice attempted to send it to you via electronic mail. Our attempts to send the document to you via electronic mail were unsuccessful. Thus, we are resending the letter today via federal express. You will notice that the enclosed letter addresses all of the discovery issues raised in your letter and email dated May 27, 2008. Therefore, we have addressed the last condition you have placed on appearing at your deposition. Due to the aforementioned communication issues, we are willing to give you one more chance to appear for your deposition before we file a motion to compel your appearance. We are available to take your deposition on June 19, 24 and 26 in our Wilmington, Philadelphia or Berwyn offices. Please let me know by Friday, June 13 at 5:00 p.m. whether you will make yourself available to be deposed on any ofthese dates. If we do not hear from you, or you respond that you are unwilling to make yourself available, given the long history of problems in attempting to schedule your deposition, we will file a motion to compel your appearance with the Court. Veery tr)tly y~ours, .
www.drinkerbiddle.com
CALIFORNIA DELN~VARE ILLINOIS NEW IERSEY NEW YORK PENNSYLVAN]A
WISCONSIN
Edward N. Yost (_//x{ ENY Enclosures cc: David J. Woolf, Esquire
Established 1849
PHLIT/916014.1
Case 1:07-cv-00555-JJF
Document 31-13
Filed 06/16/2008
Page 3 of 11
DrinkerBiddle
Law O~fices
June 10,. 2008
One Logan Square 18TH and Cherry Streets Philadelphia, PA
19103-6996
215-988-27oo phone
21.5-988-2757 fax
Via E-mail and Regular Mail Xianhua Zhang 212 Yorktown Court Malvern, PA 19355 Re: Zhang v. ING Direct Dear Mr. Zhang: I have recently received two emails from you, one dated May 27, 2008 and one dated June 3, 2008. I have also received a letter from you dated May 27, 2008. As promised, this letter responds to each of the issues that you raised in these communications, tracking the order in which you raise each issue. I. Your May 27~ 2008 Email
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CALIFORNIA DELAWARE ILLINOIS NEW JERSEY NEW YORK PENNSYLVANIA WASHINGTON DC WISCONSIN
In your May 27, 2008 e
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