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

3 Case 1 :07-cv—O0555-JJF Document 23 Filed O4/24/2008 Page 1 of 4
In the U.S. District Court for the District of Delaware
Xianhua Zhang .
Plaintiff Case No. 07-555
vs. l iii-
ING Direct . Jury Trial Demanded
Defendant _ qq
Plaintiff’s Request for Production of Documents
Addressed to Defendant- Set No. 1
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 in details related to job ad for Database Support Engineer lll posted by
Defendant on www.dice.com and other media between 1/1/05 and 12/ 1/05.
2. All documents in details related to job descriptions and requirements for Database Support
Engineer III by Defendant.
3. Resume of Plaintiff at the time of his employment application for Database Support
Engineer III posted by Defendant.
4. Restune of Dan Lu who is the replacement of Plaintiff at the time of his employment
application for Database Support Engineer lll posted by Defendant.
5. All documents in details related to background checking report for Plaintiff at the time of his
employment application for Database Support Engineer III posted by Defendant.
6. All documents in details related to background checking report for Dan Lu who is the
replacement of Plaintiff at the time of his employment application for Database Support
Engineer III posted by Defendant.
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_ Case 1:07-cv—OO555-JJF Document 23 Filed O4/24/2008 Page 2 of 4
7. All documents in details related to Defendant’s hiring of Plaintiff, including all but not limit
to: offer letters, job titles, feedback from interviews and expression of intent and etc.
8. All documents in details related to Defendant’s hiring of Dan Lu who is the replacement of
Plaintiff, including all but not limit to: offer letters, job titles, feedback from interviews and
expression of intent and etc.
9. All documents in details related to jobs assigned to Plaintiff by Defendant from 4/11/05 to
8/16/05.
10. All documents in details related to jobs assigned to Dan Lu who is the replacement of
Plaintiff by Defendant from 9/ 1/ 05 to 04/1/08.
1 1. All documents in details related to jobs assigned to other Defendant’s Oracle Database
Engineers besides Plaintiff in Database Services Team from 1/1/05 to 12/1/05.
12. All documents in details related to Plaintiff s job performance and skills by Defendant from
4/11/05to 8/16/05.
13. All documents in details related to three performance reviews for Plaintiff by Kelley Yohe,
Defendant’s Team Lead Database Services on 5/25/05, 6/22/05 and 7/12/05.
14. All documents in details related to performance reviews for Dan Lu who is the replacement
of Plaintiff by Defendant from 9/1/05 to 04/1/08.
15. All documents in details related to Defendant’s requirements for ‘typing fast’ and ‘working
fast’ as an "essential function for the position Database Support Engineer lll".
16. All documents in details related to Plaintiffs conversation with Kelley Yohe, Defendant’s
Team Lead Database Services on 7/29/06.
17. All documents in details related to Plaintiff s discharge meeting with Kelley Yohe and
Naomi Seramone HR Defendant on 8/16/05.
18. All documents in details related to two emails dated 8/25/2005 and 8/29/2005 Naomi
Seramone got from Plaintiff to ask her to return Plaintiff s personal stuff seized by
Defendant during discharge process.
19. All documents in details related to Defendant’s process and procedures to discharge people
that include but not limit to: Whether a separation letter is required? Personal and Business
time off pay? Lead time given? Handling of personal stuff`? Time to stay in company after
discharge meeting? Use of security guards? etc.
20. All doctunents in details related to Defendant’s process and procedures to authorize security
guards to confine freedom of those discharged people.
21. All documents in details filed by Defendant related to answers to questionnaires requested
by PA Bureau of UC Benefits and Allowances to Plaintiff s eligible for UC benefits.
22. All documents in details filed by Defendant with DE Department of Labor related to
Plaintiff s discharge.
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23. All documents in details related to Defendant’s Personal Time Off and Business Time Off
database showing Plaintiffs total number of Personal Time Off and Business Time Off in
hours on 8/16/2005.
24. All documents in details related to invitation and email sent to Plaintiff by Defendant
inviting him to attend. company Probation Ending meeting held around 8/ 10/2005.
25. All documents in details related to company Probation Ending meeting held around
8/ 10/2005.
26. All documents in details showing that Plaintiff s enrollment into Defendant sponsored
company 401K program.
27. All documents in details showing qualifications for employees to be enrolled into Defendant
sponsored company 401K program.
28. All documents in details showing that Plaintiffs approved vacation request for 8/18/05 and
8/19/05.
29. All documents in details showing on-call schedules for Defendant’s Database Services team
members from 04/01/05 to 04/01/06.
30. All documents in details showing qualifications for Defendant’s database engineers in
Defendant’s Database Services team to be on the on-call schedules.
31. All documents in details showing correspondences between Defendant’s Data Warehouse
team and Defendant’s Database Engineer team from 04/11/05 to 10/1/05.
32. All documents in details showing rules and items of office supplies provided by Defendant
for Plaintiff s and other employees’ daily work.
33. All documents in details related to regulations or rules authorized by Defendant to seize
personal stuff of Plaintiff and those people discharged by Defendant.
34. All documents in details related to regulations or rules authorized by Defendant not allow
Plaintiff and those people discharged by Defendant to gather their personal stuff before they
leave.
35. All documents in details related to correspondences between the Defendant and potential
witnesses used by Defendant at the trial, between Defendant and its attorneys and between
potential witnesses and Defendant’s attorneys.
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Xianhua Zhang
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Case 1:07-cv—OO555-JJF Document 23 Filed O4/24/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, Xianhua Zhang, hereby certify that a true and correct copy of the first set of Request
for Production of Documents Addressed to Defendant has 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
;< tw wruxk 4 /rw/·
ianhua Zhang
, ( , { .- Plaintiff
Date: {7 ) / P mg

Case 1:07-cv-00555-JJF

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