UNITED STATES DISTRICT COURT - Illinois Institute of ...



UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

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August Benaza,

Plaintiff,

v.

Kenilwood Police Department;

City of Kenilwood;

Officer William H. Smith,

Defendants.

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PLAINTIFF’S RULE 26(a) DISCLOSURES

I. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION.

Plaintiff reserves the right to amend its disclosures to add additional witnesses.

A. Individuals Associated With Plaintiff:

1. Bob Roberts (Owner of the Bar that Benaza frequented on the night in question)

8372 Sheridan Ave.

Chicago, IL 60661

(773) 483-8982

Information: Aware of the amount of alcohol consumed by Mr. Benaza on the night in question.

2. Dr. Wayne Chu (Benaza’s Doctor at Rush Presbyterian Hospital)

1 Presbyterian Way

Chicago, IL 60661

(312) 885-3581

Information: Aware of the injuries sustained by Mr. Benaza and the continuing rehabilitation for these injuries.

3. Dr. Nancy Steingold

83 Psych Ward Ave.

Chicago, IL 60661

(312) 772-9824

Information: Plaintiff’s emotional therapist. Aware of the psychological and emotional suffering of Plaintiff and future rehabilitation efforts.

4. Rodney Harris

9834 Presidential Way, #983

Chicago, IL 60661

(312) 870-9832

Information: Eyewitness to the events of the night in question. Drank at the bar with Plaintiff, and was a passenger in the vehicle when the Plaintiff was pulled over.

B. Individuals Associated With Defendants:

1. Officer Sandra Daniels (Head of the Kenilwood Police Internal Affairs Department)

85 Officer Ave.

Kenilwood, IL 60832

(847) 782-1835

Information: Aware of any complaints filed against Officer Smith, and Officer Smith’s reputation in the department.

2. Officer Butch King (Director of the Police Training Institute)

135 Training Center Way

Chicago, IL 60660

(312) 789-8932

Information: Has knowledge on the techniques taught to officers on various kinds of situations, including suspected drinking and driving.

3. Officer Mia Davis (Kenilwood Police Department Anger Management Director)

85 Officer Ave.

Kenilwood, IL 60832

(847) 782-1835

Information: Knowledge of Officer Smith’s temperament and ability to control his anger and possible problems concerning Officer Smith’s anger management.

4. Police Chief Warren James (Officer Smith’s superior officer and police chief)

85 Officer Ave.

Kenilwood, IL 60832

(847) 782-1835

Information: Further knowledge on Officer Smith’s history in the department, including potential claims against Officer Smith and Smith’s reputation in the department’s community.

5. Mitchell Rhea

38 Redneck Run

LeRoy, IL 60883

(314) 893-2382

Information: Officer Smith’s close friend and “drinking buddy.” Has knowledge of Officer Smith’s character at bars and is aware of Smith’s temperament.

6. Dewayne Compton

9902 Terrace Ave.

Racine, WI 60003

(302) 893-2832

Information: Officer Smith struck Mr. Compton in a bar fight in 2001 and broke his nose, apparently without being provoked or for good cause.

II. DOCUMENTS IN PLAINTIFF’S POSSESSION THAT MAY BE USED TO SUPPORT CLAIMS.

1. Kenilwood Police Department Training Manual

85 Officer Ave.

Kenilwood, IL 60832

2. Police Report Pertaining to Officer Smith’s Bar Fight in 2001.

238 Police Ave.

Racine, WI 98902

III. COMPUTATION OF DAMAGES

1. Hospital Bills For Injuries Suffered: $76,083.32

2. Pain and Suffering: $100,000.00

3. Loss of Work Pay: $1,500.00

4. Emotional Distress: $50,000.00

5. Total Damages: $227,583.32

IV. INSURANCE

1. Any Liability Coverage For The Kenilwood Police Department or the City of Kenilwood With Officer Smith As One Of Its Agents.

2. Any Liability Coverage That Officer Smith May Possess Himself As A Police Officer.

Dated: November 9, 2004 By:________________________________

Jacob Eckburg

Eckburg & Associates

9820 Lawyers Way

Chicago, IL 60661

(312) 892-0834

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