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

Case 1 :07-cv-00431-GIVIS Document 28 Filed 04/11/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOSEPH J ADCZAK and CATHERINE )
JADCZAK, )
)
Plaintiffs, )
)
v. ) C.A. N0. 07-431 (GMS)
)
HOMESITE INSURANCE COMPANY, )
)
Defendant. )
DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
DIRECTED TO PLAINTIFFS
Pursuant to Federal Rule of Civil Procedure 34, and subject to the Definitions and
Instructions set forth below, Defendant Homesite Insurance Company ("Homesite"), by and
through its undersigned counsel, hereby requests that Plaintiffs Joseph Jadczak and Catherine
J adczak ("Plaintiffs") produce or permit Defendant to inspect and copy the original documents
and things described herein no later than thirty (30) days aiier service of these requests, at the
law offices of Cozen O’Connor, 1201 North Market Street, Wilmington, Delaware 19801.
DEFINITIONS
A. The uniform definitions set forth in the Local Civil Rules of the United States District
Court of the District of Delaware are incorporated by reference as if fully set forth herein.
B. "You" or "Your" shall mean plaintiffs, Joseph and Catherine Jadczak and any of their
employees, attorneys, agents or representatives and all other persons acting on their behalf.
C. To the extent that requested documents have already been produced, please identify those
documents in response hereto.
INSTRUCTIONS
These instructions are not to be interpreted to limit, in any way, applicable instructions
under the Federal Rules of Civil Procedure, and the instructions should be given the most liberal
interpretations so as to provide for the broadest appropriate discovery as possible.

Case 1:07-cv—00431-G|\/IS Document 28 Filed 04/11/2008 Page 2 of 3
A. In responding to these Requests, you are required to furnish all information available to
you, including, but not limited to, information in the possession or control of your attorneys,
experts, advisors, agents or associates.
B. If any information requested herein is claimed to be privileged or otherwise protected
from discovery, you are requested to identify in writing, with particularity, the basis for such
claim(s), and - in the case of any document withheld from production - to identify in writing
consistent with the applicable Rules of Civil Procedure;
(l) its author;
(2) the recipients;
(3) the date of creation/receipt;
(4) its general nature and subject matter;
(5) its present location and custodian; and
(6) the basis upon which it is claimed to be privileged or otherwise protected from
discovery or withheld from production.
C. You are requested and obligated to supplement your answers to these Requests as
additional information becomes available to you at any time during the pendency of this matter.
DOCUMENT REQUESTS
l. All documents identified in your responses to Homesite’s Interrogatories to Plaintiffs.
2. A complete, certified copy of each and every policy identified by you in your answer to
Homesite’s lnterrogatories served herewith.
3. A copy of each and every receipt or other document you relied upon in arriving at the
total amount you claim Homesite failed to pay you, as outlined in your answer to
Homesite’s interrogatories served herewith. For items for which you are claiming
coverage as "contents," please produce a copy of each and every document evidencing
the date said item was purchased, from whom it was purchased, the paid purchase price
and condition of the item at the time of purchase.
4. lf you have consulted with or retained any expert witnesses, please provide a copy of any
and all reports they have provided or prepared, whether final or draft versions, along with
any and all notes and/or correspondence of any kind whatsoever relating to those reports.
5. A copy of any and all documents you have and/or are aware of that support the
allegations made by you that Homesite failed to timely or fully adjust your claim.
6. A copy of any and all documents you have and/or are aware of that support the
allegations made by you that Homesite breached its contract with you regarding the
handling of your claim.
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Case 1:07-cv-00431-GIVIS Document 28 Filed 04/11/2008 Page 3 of 3
7. A copy of any and all documents you have and/or are aware of that support the
allegations made by you that Homesite acted in bad faith regarding the handling of your
claim.
8. A copy of any and all exhibits that you intend to use at the trial of this matter.
9. A copy of any and all checks, receipts or other documents that you believe evidence your
repair and/or replacement of any damage caused by the May 29, 2006 fire.
10. A copy of any and all photographs, estimates, applications, correspondence or other
documents that you contend support your claim for damages in this action.
11. A copy of any and all documents, including but not limited to mortgage papers, that
evidence your ownership of the property you allege is covered by your Homesite policy
of insurance.
12. A copy of any and all documents that evidence your ownership of the recreational vehicle
you allege is covered by your Homesite policy of insurance.
13. A copy of each and every document you relied upon in determining the total amount of
your claim for Additional Living Expenses (ALE).
14. A copy of each and every document you would rely upon to prove the occurrence,
content, date or any other element concernin; each and every contact or communication
you claim to have made with Homesite . any tim from May 29, 2006 to the present.
15. All documents you intend to offe as ex at t al.
I D
D ,
Dated: April ll, 2008 $
ew (#4072)
Cozen O’Connor
1201 N. Market Street, Suite 1400
Wilmington, DE 19801
Telephone: (302) 295-2000
Facsimile: (302) 295-2013
Counsel for Defendant
OF COUNSEL:
Melissa F. Brill, Esquire
Cozen O’Connor
45 Broadway Atrium, 16th Floor
New York, NY 10006
Telephone: (212) 509-9400
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