Free Request for Admissions - District Court of Delaware - Delaware

A Case 1 :07-cv-00479-SLR—LPS Document 14 Filed 05/O2/2008 Page 1 of 4
. IN THE UNITED STATES DISTRICT COURT
i FOR THE DISTRICT OF DELAWARE
MAJED SUBH, )
Plaintiff g
v. g C.A. No. 07~479 SLR
WAL—l\/[ART STORES EAST, LP, g
Defendant. g
DEFENDANTS REQUEST FOR ADMISSIONS
DIRECTED TO PLAINTIFF
Pursuant to Federal Rule of Civil Procedure 36, Defendant Wal~i\/Iart Stores East, LP
("Wal~Mart”) hereby requests that Plaintiff Maj ed Subh admit the truth ofthe following matters
in accordance with the definitions and instructions set forth below. A true copy ofthe answers to
these requests for admission and any objections defendant may have to these requests for
admission must be served on the undersigned attorney at the offices of Potter, Anderson &
Corroon LLP, Hercules Plaza, l3l3 North Market Street, Wilmington, DE 19SOl , within 30 days
of the date of these requests.
DEFINITIONS
The definitions set forth in Wal-Mart’s First Request for Production of Documents
Directed to Plaintiff are incorporated and restated as if fully set forth herein.
INSTRUCTIONS
l. With respect to each ofthe following requests for admission, if you cannot admit
or deny all or any part ofthe request, you shall (a) specifically identify such request or part
‘ thereof that you cannot admit or deny and set forth in detaii the reasons why you cannot admit or
deny the request or part thereof, and (b) admit or deny any remaining part of such request.

Case 1:07-cv-00479-SLFi—LPS Document 14 Filed 05/O2/2008 Page 2 of 4
2. With respect to each ofthe following requests for admission, if you claim lack of
knowledge as a reason for failure to admit or deny the request or any part thereof, you shall
; detail the extent ofthe inquiry made and aftinn that the information known or readily attainable
to you is insufficient to allow you to admit or deny the request or part thereof.
3. With respect to each ofthe following requests for admission, if you deny all or
any part of the request, you shall set forth in detail the basis for that denial.
4. Each request for admission shall be construed independently and not with
reference to any other request for admission for the purpose of limitation or exclusion.
5. These requests for admission shall be deemed continuing and, in the event that
circumstances change so that a response no longer is correct, said response shall be amended.
REQUESTS FOR ADMISSION

Admit that you pleaded "no contest" to the criminal charge of menacing arising out of an
encounter you had with Ruth McPherson at Wal—Mart Store #5436 on or about April 13, 2007.
Request N0. 2
1 Admit that you did not tile a charge of discrimination with the Delaware Department of
Labor or Equal Employment Opportunity Commission that asserted you had been subjected to
sex or gender discrimination while employed by Wal-Mart.
C Admit that you did not tile a charge of discrimination with the Delaware Department of
Labor or Equal Employment Opportunity Commission that asserted you had been subjected to
. sexual harassment while employed by Wal-Mart.
Request N0. 4
Admit that both you and Cathy Brown were informally coached to act professionally at
work following complaints you lodged against each other in May 2006.
Reguest N0. 5
l 2

Case 1:07-cv-00479-SLR—LPS Document 14 Filed 05/O2/2008 Page 3 of 4
E Admit that you did not receive any discipline as a result of Ms. Browrfs complaints
against you.
Reguest No. 6
. Admit that, prior to the charge of discrimination you filed with the Delaware Department
( of Labor on June 14, 2006, you did not complain to any member of management or human
resources at Wal-Mart that you felt you had been subjected to inappropriate comments based
upon your race or national origin.
Reguest No. '7
p Admit that the Verbal Coaching that you received on or about July 13, 2006 was based
on an accurate statement of events in which you refused to follow the directions of an assistant
manager.
Reguest No. 8
Admit that the Written Coaching you received on or about August 7, 2006 was based on
an accurate statement of events in which you attempted to faisify your time records.
Reguest No. 9
Admit that the Decisiou—Making Day Coaching you received on or about October 31,
A 2006 was based on an accurate statement of events in which you engaged in a verbal altercation
with a co-worker in view of customers.
Reguest N0. 10
Admit that you requested, and were permitted, to transfer to Store #5450 in Northeast,
Maryland.
l POTTER. ANDERSON & CORROON LLP
By: /s/ Sarah E. DiLuzi0
E Kathleen Furey McDonough (LD. 2395)
Sarah E. DiLuzio (I.D. 4085)
l3l3 North Market Street, P.O. Box 951
Wilmington, DE 19899-0951
Telephone: (302) 984-6000
Telefax: (302) 658-1192
j [email protected]
1 sdilu.zio@_nctteranderson.com
1 Attorneys for Dejhndam Wal-Mar! Stores East, LP
Dated: May 2, 2008
E sszmxszisz

I Case 1:07-cv-00479-SLR—LPS Document 14 Filed 05/O2/2008 Page 4 of 4
CERTIFICATE OF SERVICE
p I, Sarah E. DiLuzio, hereby certify that on May 2, 2008, a true and correct copy of the
foregoing DEFENDANTS REQUEST FOR ADMISSIONS DIRECTED TO PLAINTIFF was
mailed via Federal Express to plaintiff at the following address:
Maj ed Subh, pro se
204 Latimer Street
Apt. 2
Wilmington, DE 19804

/s/ Sarah E. DiLuzi0
Sarah E. Dilcuzio (#4085)
Porraa ANoERs0N & Coaaoors LLP
_ Hercules Plaza, 6th Floor -
1313 North Market Street
P.O. Box 951
Wilmington, DE 19899-0951
Telephone: (302) 984—6000
Telefax: (302) 658-1192 y
E-mail: sdiluzioggzgotteraraderson.com
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