Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:07-cv-00541-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KENZA L. STARLING, Plaintiff, v. JOHN E. POTTER, Postmaster General United States Postal Service, Defendant. : : : : : : : : :

Civil Action No. 07-541-JJF

RULE 26(a)(1) INITIAL DISCLOSURES COMES NOW, Defendant John E. Potter, Postmaster General of the United States, by his attorneys, Colm F. Connolly, United States Attorney for the District of Delaware, and Lesley F. Wolf, Assistant United States Attorney, pursuant to Potters's obligations under Fed. R. Civ. P. 26(a)(1)(A), and discloses the following: Rule 26(a)(1)(A)(I) 1. Valerie Michaelis

Ms. Michaelis has information regarding plaintiff's behavior and the facts surrounding plaintiff's allegations of harassment.

2.

Donna Wdzieczkowski U.S. Postal Service South Jersey, P& DC

Ms.Wdzieczkowski has information regarding plaintiff's behavior and the facts surrounding plaintiff's allegations of harassment. 3. Joseph Vennera U.S. Postal Service South Jersey, P& DC

Mr. Vennera has information regarding start times on holidays and why he denied plaintiff's requested schedule change.

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4.

Richard Weissman U.S. Postal Service South Jersey, P& DC

Mr. Weissman has information regarding plaintiff's leave from 5/22/04-5/27/04 and the request for updated medical information. 5. Charles Thatcher Mr. Thatcher has information regarding a meeting he allegedly missed with plaintiff. 6. Dave Harvey U.S. Postal Service South Jersey, P& DC Mr. Harvey has information regarding FMLA approval. 7. Bob Steelman U.S. Postal Service South Jersey, P& DC Mr. Steelman has information regarding plaintiff's time card allegations. 8. Vicki Ago U.S. Postal Service South Jersey, P& DC Ms. Ago has information regarding plaintiff's AWOL charge. 9. Carla Dunn U.S. Postal Service Eastern Area, Pittsburgh Ms. Dunn has information regarding plaintiff's limited duty job offer. 10. Dee Baranoski U.S. Postal Service South Jersey, P& DC Ms. Baranoski has information regarding plaintiff's behavior on June 2-3, 2004. 11. Cindy Thorson U.S. Postal Service South Jersey, P& DC Ms. Thorson has information regarding the dress policy (related to footwear) on the

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workroom floor. 12. Barbara Neil U.S. Postal Service South Jersey, P& DC

Ms. Neil has information regarding plaintiff's medical file and the requirements and needs for special chairs. 13. Bill Wiand U.S. Postal Service South Jersey, P& DC Mr. Wiand has information regarding plaintiff's behavior on June 2, 2004. 14. Wendy Pezzi Workplace Improvement Analyst South Jersey District Ms. Pezzi has information regarding communications with plaintiff. 15. Gerald Golden U.S. Postal Service South Jersey, P& DC

Mr. Golden has information regarding assistance he provided to plaintiff and postal management officials. 16. Mary Deal U.S. Postal Service South Jersey, P& DC Ms. Deal has information regarding her observations of plaintiff during the relevant time period. 17. Janice Johnson Occupational Health Nurse Administrator Ms. Johnson has information regarding plaintiff's medical records. 18. Kenza Starling Ms. Starling has information regarding all of the allegations in the Complaint.

Rule 26(a)(1)(A)(ii)

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1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14.

Administrative Hearing Transcript EEO Report of Investigation 7-04 Clock Rings 10/6/06 Agency's Proposed Exhibits Ms. Starling's Pre-hearing Statement and Witness List Ms. Starling's Pre-hearing Statement-- additional information Agency Pre-Hearing Statement Telephonic Bench Decision Order Entering Judgment Deposition of Kenza Starling Pre-hearing Order OFO Appeal File OWCP File 2004 Tacs Report for Kenza Starling On information and belief, plaintiff is already in possession of these documents.

Rule 26(a)(1)(A)(iii) Not applicable. Rule 26(a)(1)(A)(iv) Not applicable.

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Dated: May 6, 2008 Respectfully Submitted, COLM F. CONNOLLY United States Attorney By: s/Lesley F. Wolf Lesley F. Wolf Assistant United States Attorney The Nemours Building 1007 Orange Street, Suit 700 Wilmington, DE 19801 (302) 573-6277

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CERTIFICATE OF SERVICE I, Lesley F. Wolf, Assistant United States Attorney for the District of Delaware, hereby certify that on the 6th day of May 2008, a copy of the foregoing Initial Disclosures was sent via U.S. mail to:

Kenza L. Starling 5105 Christiana Meadows Bear, DE 19071

______s/Lesley F. Wolf___________ Lesley F. Wolf Assistant United States Attorney