Rule 26(a) Initial Disclosure - Chicago-Kent College of Law



Rule 26(a) Initial Disclosure

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

)

Mr. Binaza, )

)

Plaintiff, )

)

v. )

)

Officer Smith; Kenilworth )

Police Department )

)

Defendants. )

)

PLAINTIFF'S RULE 26(a)(1) INITIAL DISCLOSURES

I. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION THAT MAY BE USED TO SUPPORT PLAINTIFF'S CLAIMS:

Plaintiff’s initial disclosure is made without the benefit of any discovery and prior to Defendants’ answers. Plaintiff reserves the right to amend its disclosures to add additional witnesses.

A. INDIVIDUALS ASSOCIATED WITH PLAINTIFF

1. Dr. Hugh Jackman

123 Marshfield

Chicago, IL 60657

Information Includes: Diagnosis and treatment of Plaintiff's injuries in the early morning of September 22, 2004;

2. Ms. Ima Narc

321 Tattletale Dr.

Kenilworth, IL 60600

Information Includes: knowledge of the events the night of September 21, 2004.

B. INDIVIDUALS AND ENTITIES AFFILIATED WITH DEFENDANT

1. Mr. Trey Knor

579 Itrain Rd.

Kenilworth, IL 60600

Information Includes: full knowledge of officer training with Kenilworth Police Department employees

2. Mr. Michael Patrick

987 Dispatcher Ln.

Kenilworth, IL 60600

Information Includes: full knowledge of dispute; contact with Officer Smith on the night of September 21, 2004.

3. Kenilworth Police Department

100 Kenilworth St.

Kenilworth, IL 60600

Information Includes: knowledge of dispute; knowledge of officer training for Kenilworth Police Department employees

C. THIRD PARTY WITNESSES

1. Mr. Loghan Hunter

321 Witness Dr.

Kenilworth, IL 60600

Information Includes: knowledge of the events the night of September 21, 2004.

2. Ms. Mattison Lee

789 Spectator Dr.

Kenilworth, IL 60600

Information Includes: knowledge of the events the night of September 21, 2004.

II. CATEGORIES AND LOCATIONS OF DOCUMENTS

1. Documents relating to Officer Training Sessions; including but not limited to material covered at session, attendance lists of Officers attending.

2. Documents related to previous disciplinary action of Kenilworth Officers; including but not limited to names of officers reprimanded and purposes for reprimand.

3. Documents related to standard issue officer equipment; including but not limited to equipment that the officer's carry, including physical specs.

III. COMPUTATION OF DAMAGES

Mr. Binaza has suffered damages as follows:

1) Approximately $10,000 in medical expenses.

2) Approximately $80,000 in pain and suffering.

3) Approximately $10,000 in legal fees incurred this far.

Total Damages: $100,000.

IV. INSURANCE

Plaintiff, at this time, is not aware of any insurance agreement under which any persons carrying on an insurance business may be liable to satisfy all or part of a judgment which may be entered in favor of Plaintiff or to indemnify or reimburse Defendants for payments to satisfy the judgment.

Dated: November 9, 2004 By:

Rachel A. Lynch

LYNCH & SWAIN, LLC

2020 Abbey Road

Chicago, IL 60657

(312) 867-5309

rlynch@lynch&

ATTORNEY FOR PLAINTIFF

MR. BINAZA

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