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

Case 1:07-cv-00505-SLR

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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE KEVIN A. APGAR, Plaintiff, v. WARDEN RAPHAEL WILLIAMS, DR. BINNON, JAMES WELCH, Defendants. -----------------------------------------------------) ) ) ) ) ) ) ) )

Case No. 07-505 (SLR) JURY TRIAL DEMANDED

DEFENDANT DR. BINNON'S FIRST SET OF REQUESTS FOR PRODUCTION DIRECTED TO PLAINTIFF Defendant Dr. Binnon, by and through his undersigned counsel, requests production of the following documents within thirty (30) days from the date hereof at the offices of Balick & Balick LLC, 711 King Street, Wilmington, Delaware: REQUESTS 1. All documents1 referred to in Plaintiffs' Answers to Interrogatories.

RESPONSE:

2.

Copies of all documents which are relevant, in whole or in part, to

plaintiff's claim for damages (including but not limited to medical reports, income and tax records). RESPONSE:

1

All definitions and instructions contained in Dr. Binnon's First Set of Interrogatories are incorporated herein by reference.

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3.

Copies of all documents which are relevant, in whole or in part, to

plaintiff's claim for lost wages. RESPONSE:

4.

If you claim any loss of support, loss of income, loss of future income, or

impairment of earning capacity in this lawsuit, please produce Federal and State income tax returns for the years 1998 through the present. RESPONSE:

5.

Copies of any hospital records, test results, examination results or reports,

office notes, correspondence, or any other matter in writing whatsoever pertaining to your physical, mental, or emotional condition at any time or any treatment or examinations or tests concerning your health. RESPONSE:

6.

Correspondence or written or recorded report made by each physician or

other medical personnel to whom you have gone for consultation or examination concerning your physical, mental, or emotional condition. RESPONSE:

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7.

All documents submitted to or received from any expert.

RESPONSE:

8.

Every photograph, diagram or other pictorial representation(s) upon which

you intend to rely at trial. RESPONSE:

9.

Copies of all bills and receipts evidencing payment of bills for which the

plaintiff seeks compensation in this lawsuit. RESPONSE:

10.

Copies of the curriculum vitae of all experts you intend to call at trial.

RESPONSE:

11. plaintiff.

Any journals, diaries, logs or other documents or recordings kept by the

RESPONSE:

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12.

All documents, including but not limited to texts, journals, treatises,

correspondence, and memoranda upon which any expert retained by you in connection with this lawsuit relies in forming his or her opinion. RESPONSE:

BALICK & BALICK L.L.C.

/s/ James E. Drnec James E. Drnec (DE Bar # 3789) 711 King Street Wilmington, DE 19801 (302) 658-4265 Attorneys for Dr. Binnon Dated: June 3, 2008

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CERTIFICATE OF SERVICE I, James Drnec, hereby certify that on the 3rd day of June 2008, the foregoing Defendant Dr. Binnon's First Set of Requests for Production Directed to Plaintiff was filed via CM/ECF and served upon the following in the manner indicated:

Kevin A. Apgar SBI# 302981 Howard R.Young Correctional Institution P.O. Box 9561 Wilmington, DE 19809 Stacey X. Stewart, Esquire Department of Justice State of Delaware 820 N. French Street, 8th Floor Carvel Office Building Wilmington, DE 19801

VIA FIRST CLASS MAIL

VIA CM/ECF FILING

/s/ James E. Drnec James E. Drnec, Esquire (#3789)