Free Response to Discovery - District Court of Delaware - Delaware

Case 1 :07-cv—O0555-JJF Document 22 Filed O4/24/2008 Page 1 of 4
In the U.S. District Court for the District of Delaware
Xianhua Zhang V ' 3 ‘1 i il .
Plaintiff ; Case No. 07-555
APR 24 ZUU8 _
vs. L i § A
i I "T`§'iri§E"t€Eii?”?;3o _
ING Dif€C1 g DiSTRIC )F JEUE AR __ lA,__t_ _ Jury Trial Demanded
Defendant @0 5¢a.n~r»\»
Plaintiffs Responses t0 Request for
Production of Document Set One from Defendant
1. Three performance reviews for Plaintiff by Kelley Yohe, Defendant’s Team Lead Database
Services; job offer letter; job description for Database Support Engineer III — Oracle (Database
Administrator); ING Direct Standard Employment Terms and Conditions; ING Direct 401(K)
and PS Plan; two emails I sent to Naomi Seramone HR Defendant and
Employee+Handbook+2005-06.15. Evidences in Complaint, Plaintiffs Pleading to Defendant
ING Direct’s Affirmative Defenses, Plaintiff s Request for Production of Documents Addressed
to Defendant and Plaintiff s Interrogatories Directed to Defendant and Plaintiff s Responses to
Interrogatories Set One from Defendant.
2. Same as No. 1.
3. Same as No. 1.
4. Same as No. 1.
5. Offer letter. Evidences in Complaint, Plaintiffs Pleading to Defendant ING Direct’s Affirmative
Defenses, Plaintiff s Request for Production of Documents Addressed to Defendant and
Plaintiff s Interrogatories Directed to Defendant.
6. Same as No. l.
7. I am now still receiving treatment to cure my serious impairments caused by traffic accident on
1/24/2003. Since Defendant is asking for Plaintiffs authorization to release all medical records
related to this accident and Plaintiff is going to provide such authorization, there is no need for
duplicate efforts to send those records.
8. Same as No. 7.
9. Same as No. 7.
10. Objection. This request exceeds the scope of permissible discovery related to this case as being
broad, unreasonable, burdensome and unduly oppressive. Nevertheless, I did get $7472 of
unemployment compensation after 8/16/05 and before I started to work for CDI as DBA-Oracle
since the end of l 1/05. This is a consultant job with hourly rate of $53 without any benefits.
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_ Case 1:07-cv—OO555-JJF Document 22 Filed O4/24/2008 Page 2 of 4
11. Objection. This request exceeds the scope of permissible discovery related to this case as being
broad, unreasonable, burdensome and unduly oppressive.
12. I have been working with CDI as DBA-Oracle since the end of 11/05. It is a normal and high
level Oracle DBA job requiring many years of extensive Oracle database administration
experience to manage complicated Oracle databases but no perl experience required like all
other Oracle DBA jobs.
13. Same as No. 1.
14. Same as No. 1.
15. Same as No. l.
16. Same as No. 5.
17. Same as No. 5. Monetary harm of $61079 that includes the following items calculated based on
my annual salary $85000 and benefits: Bonus equal to 18% of salary for 4.25 months is $5418.
Eight day of PTO pay is $2720. Four hours of business time off is $170. Profit sharing equal to
2% of salary is $602. ING Direct also kept many of my personal belongings such as staples,
tape, pens (ING Direct does not provide any office supplies.) and many technical printings that I
brought from home with value about $40. In addition, the salary for my unemployment period of
3.5 months with benefits — 18% bonus, 2% profit sharing and 7 days of PTO equal to $32129
plus cost of $20000 for health insurance from 9/05 up to now. Besides, the unlawful discharge
was also a heavy blow to me mentally. The value of that loss and cost of health insurance for the
future eight years will be decided by Judge and Jury during the trial.
18. Same as No. 1.
19. Same as No. 1.
20. Same as No. l.
21. Objection. This request exceeds the scope of permissible discovery as it seeks information and
documents protected by attorney client privilege.
22. Objection. This request exceeds the scope of permissible discovery related to this case as being
broad, unreasonable, burdensome and unduly oppressive.
23. Objection. This request exceeds the scope of permissible discovery related to this case as being
broad, unreasonable, burdensome and unduly oppressive.
24. Same as No. 1.
25. Same as No. 1.
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26. Same as N0. 1.
27. Same as No. 1.
28. Same as N0. 1.
29. Same as N0. 1.
30. Same as N0. 1.
31. Same asNo. l.
32. Same as N0. 1.
33. Same as N0. 1.
34. Same as N0. 1.
35. Same as N0. 1.
36. Evidences in Complaint, Plaintiffs Pleading to Defendant ING Direcfs Affirmative Defenses,
Plaintiffs Request for Production of Documents Addressed to Defendant and Plaintiff s
Interrogatories Directed to Defendant and Plaintiff s Responses to Interrogatories Set One from
Defendant.
37. Same as N0. 1.
38. Same as No. 1.
39. Same as N0. 1.
40. Same as No. 1.
41. Answers to interrogatories 10, 13 and 14. See reply to Request No. 7. Evidences in Complaint,
Plaintiffs Pleading to Defendant ING Direct’s Affirmative Defenses, Plaintiffs Request for
Production of Documents Addressed to Defendant and Plaintiff s Interrogatories Directed to
Defendant and Plaintiffs Responses to Interrogatories Set One from Defendant.
§<\O*/'~'~/Li4»\/lin, 2/Qty ” ,
Xianhua Zhang
` Plaintiff
Date: (7l
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I Case 1:07-cv—OO555-JJF Document 22 Filed O4/24/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, Xianhua Zhang, hereby certify that a true and correct copy of Plaintiff s Responses to
Request for Production of Document Set One from 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] — Attomey for Defendant
` \ I n . *7
Xianhua Zhang
p Piaimirr
Date: [ 2 me

Case 1:07-cv-00555-JJF

Document 22

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