Free Initial Disclosures - District Court of Delaware - Delaware

Case 1 :O7—cv-00555-JJF Document 18 Filed O2/29/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
XIANHUA ZHANG
Plaintiff, Case N0. 07-555 (UF)
v.
mc onzacr i
Defendant.
DEFENDANT ING BANK, FSB’S INITIAL DISCLOSURES PURSUANT TO
FEDERAL RULE OF CIVIL PROCEDURE 26ga)g1[
Defendant ING Bank, fsb ("ING Bank"), improperly identified in the
Complaint as ING Direct, by and through its undersigned attorneys, makes the following
initial disclosures pursuant to Rule 26(a)(l) of the Federal Rules of Civil Procedure.
These disclosures are subject to supplementation and/or modification, and they are
provided without prejudice to or waiver of any privilege or objection ING Bank may
have to any subsequent discovery by Plaintiff.
I. Individuals Likely to Have Discoverable Information That ING Bank May
Use to Support Its Defenses.
A. Kelley Yohe ‘
Ms. Yohe has knowledge pertaining to Plaintiff s employment with ING Bank;
Plaintiff s job duties, performance and workplace conduct; Plaintiffs compensation at
ING Bank; the circumstances concerning Plaintiff" s separation; and the allegations
Plaintiff makes about her and other allegations in the Complaint. Ms. Yohe may only be
contacted through counsel for ING Bank.

Case 1:O7—cv-00555-JJF Document 18 Filed O2/29/2008 Page 2 of 3
B. Naomi Seramone
Ms. Seramone has knowledge pertaining to Plaintiffs employment with ING
Bank; Plaintiffs job duties, performance and workplace conduct; Plaintiff s
compensation with ING Bank; the circumstances concerning Plaintiff s separation; and
other allegations in the Complaint. Ms. Seramone may only be contacted through
counsel for ING Bank.
C. Yan Shi
Mr. Shi has knowledge pertaining to Plaintiffs employment with ING Bank;
Plaintiffs job duties, performance and workplace conduct and other allegations in the
Complaint.
II. Description of All Documents in Defendant’s Possession, Custody, or Control
That It May Use to Support Its Defenses.
A. Documents conceming Plaintiff s job perfonnance when employed by
ING Bank.
B. Plaintiff s EEOC Charge of Discrimination and related documents.
C. Documents subsequently produced by either party and any non—party
during discovery.
Defendant reserves the right to supplement this list.
III. Computation of damages claimed by Defendant.
Defendant does not claim damages at present.
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Case 1:O7—cv-00555-JJF Document 18 Filed O2/29/2008 Page 3 of 3
. IV. Insurance Agreements Under Which An Insurance Business May Be Liable
T0 Satisfy or to Indemnify or Reimburse Defendant ING Bank for All or
Part of a Judgment.
Defendant ING Bank is currently investigating whether it has any insurance
policy that will satisfy, indemnify or reimburse it for any judgments conceming this
lawsuit and will supplement its response as appropriate.
Dated: February 27, 2008 &"—
David P. Primack (I.D. No. 4449)
DRINKER BIDDLE & REATH LLP
1100 N. Market Street
Wilmington, DE 19801-1254
(302) 467-4220
(302) 467-4201 fax
Attomeys for Defendant/Counterclaim Plaintiff
ING Bank, fsb
OF COUNSEL:
David J. Woolf (admitted pm hac vice)
Edward N. Yost (admitted pro hac vice)
DRINKER BIDDLE & REATH LLP
One Logan Square
18th & Cherry Streets
Philadelphia, PA 19103
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