PLAINTIFF S INITIAL DISCLOSURES

Similar documents
Plaintiff, DEFENDANT'S INTERROGATORIES, REQUEST. Defendant. City of Bloomington ( Bloomington ) and demands that Plaintiff Tony Webster ( Webster )

Case 1:06-cv JJF Document 14 Filed 03/19/2007 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Federal Rules of Civil Procedure

Rule 26. General Provisions Governing Discovery; Duty of Disclosure [ Proposed Amendment ]

CASE MANAGEMENT PROTOCOL OAKLAND COUNTY CIRCUIT COURT BUSINESS COURT CASES

Plaintiff, Defendant. PLEASE TAKE NOTICE that Plaintiff Acme Home & Garden, LLC demands answers

Filing an Answer to the Complaint or Moving to Dismiss under Rule 12

Case 2:05-cv TJW Document 211 Filed 12/21/2005 Page 1 of 11

REPUBLICAN RIVER WATER CONSERVATION DISTRICT S RULE 26(a)(1) DISCLOSURES

Discovery Requests in Trademark Cases Under U.S. Law

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND

No. A STATE OF MINNESOTA SUPREME COURT. Tony Webster, vs. Hennepin County and the Hennepin County Sheriff s Office,

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY NAME]

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. JOINT RULE 26(f) PRETRIAL REPORT vs.

Plaintiff, Defendant. GENERAL OBJECTIONS. 1. The following responses are without in any way waiving or intending to waive:

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE. A court authorized this Notice. This is not a solicitation from a lawyer.

Woods et al v. Vector Marketing Corporation Doc. 276 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA

v. GUADALUPE COUNTY, TEXAS

RULE CHANGE 2018(06) COLORADO RULES OF CIVIL PROCEDURE

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) )

This matter came on for court trial before the Honorable Mark A. Labine, Referee of District Court, on December 13, 2017.

STATE OF ARIZONA MARICOPA COUNTY SUPERIOR COURT. Plaintiff, Defendants.

STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT: The only way to potentially receive money from this Settlement.

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

To: Morgan Smith, th Street SE, Minneapolis, MN For the purpose of these discovery requests, the following definitions apply:

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION. Case No. 5:07-CV-231

IN THE SUPERIOR COURT OF DOUGHERTY COUNTY STATE OF GEORGIA ) ) NOTICE OF CLASS ACTION SETTLEMENT

Case 1:18-cv PGG Document 1 Filed 10/24/18 Page 1 of 6

STATE OF MINNESOTA DISTRICT COURT SECOND JUDICIAL DISTRICT COUNTY OF RAMSEY. Case Type: Civil/Other. Andrew Cilek and Minnesota Voters Alliance,

(2) Date of entry of judgment or date of service of notice of filing of order from which appeal is taken:

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION

JURISDICTION AND VENUE

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

CASE 0:13-cv JRT-JJK Document 1 Filed 08/26/13 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA ) ) ) Civil Action

1. TRCP 194 created a new discovery tool entitled Requests for Disclosure.

MINNESOTA JUDICIAL TRAINING UPDATE PARENTING TIME EXPEDITOR VS PARENTING CONSULTANT

Case 2:10-cv RLH -GWF Document 63-1 Filed 01/28/11 Page 1 of 6 EXHIBIT A

IF YOU RECEIVED A PHONE CALL ABOUT A CASH FOR RELOCATION PROGRAM OFFERED BY ALTISOURCE, YOU COULD RECEIVE A PAYMENT FROM A CLASS ACTION SETTLEMENT.

UNITED STATES DISTRICT COURT

CAUSE NO. PLAINTIFF S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE. NOW COMES Plaintiff, Stephen Torres, and files this, his Original Petition

4:12-cv GAD-DRG Doc # Filed 09/21/15 Pg 1 of 82 Pg ID 4165 EXHIBIT 2

Case 2:06-cv JLL-CCC Document 55 Filed 03/27/2008 Page 1 of 27

PROFESSIONAL SERVICES AGREEMENT (Contingent Fee Special Counsel for Environmental Litigation)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. CASE NO Civ-King. Plaintiffs,

Plaintiffs LEAGUE OF UNITED LATIN AMERICAN CITIZENS (LULAC), HERLINDA S. GARCIA, JUAN GARCIA, AGUSTIN PINEDA, BERTA URTEAGA,

IN THE COURT OF APPEALS OF MARYLAND R U L E S O R D E R. This Court s Standing Committee on Rules of Practice and

Mall of America App. End User License Agreement

Your legal rights may be affected even if you do not act. Please read this Notice carefully. YOUR RIGHTS AND CHOICES

You Can Get Benefits from a Class Action Settlement with CubeSmart

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA

Court File No

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA CASE NOS.

Gottschlich & Portune, LLP

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION. versus Civil Action 4:17 cv 02946

CODE OF PROCEDURE FOR RESOLVING EMPLOYMENT DISPUTES

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA CHARLOTTESVILLE DIVISION

CASE 0:15-cv DWF-JSM Document 1-1 Filed 12/24/15 Page 1 of 14 ) ) ) ) ) ) ) ) ) ) ) THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANT:

Virginia Freedom of Information Act ( VFOIA ) Complaint Template

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH

CIRCUIT COURT OF MULTNOMAH COUNTY, OREGON

CITY OF FROM: Chelsea Petersen, Assistant City Manager CHANHASSEN

ELECTRIC FRANCHISE ORDINANCE ORDINANCE NO. 99. CITY OF MEDICINE LAKE, HENNEPIN COUNTY, MINNESOTA

EXHIBIT J To THE DECLARATION OF HOLLY GAUDREAU IN SUPPORT OF MOTION FOR EXPEDITED

CLASS ACTION COMPLAINT. NOW COMES the Plaintiffs and as Complaint against the above-named Defendants aver SUMMARY OF CLAIMS

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SETTLEMENT AGREEMENT

STATE OF WISCONSIN CIRCUIT COURT SHEBOYGAN COUNTY

New Jersey False Claims Act

IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS CIVIL COURT DEPARTMENT : : : : : : : : : : : : : : Case No. 08-CV Division No.

GENERAL ORDER FOR LUCAS COUNTY ASBESTOS LITIGATION. damages for alleged exposure to asbestos or asbestos-containing products; that many of the

Section 1: Statement of Purpose Section 2: Voluntary Discovery Section 3: Discovery by Order of the Court... 2

C I T Y O F H E R M O S A B E A C H M E M O R A N D U M

CODE OF PROCEDURE FOR RESOLVING BUSINESS-TO-BUSINESS DISPUTES

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION ) ) ) ) ) ) UNIFORM SCHEDULING ORDER

A Live 90-Minute Teleconference/Webinar with Interactive Q&A

If you are a current or former paying member of Angie s List, Inc., you may get a payment or benefit from a proposed Class Action Settlement.

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

Case 0:10-cv MJD-FLN Document 1 Filed 04/06/10 Page 1 of 14 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Court File No.

Roger T. Castle 1888 Sherman Street, Suite 415 Denver, CO DEFENDANT S MOTION TO COMPEL

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND. v. * Case No. 17-cv-2006-EH * * * * * * * * * * * * *

A federal court authorized this notice. This is not a solicitation from a lawyer.

Plaintiffs St. Louis Park Echo ( The Echo ), Maggie Bahnson, individually and as

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

Case 1:14-cv TSC Document 113 Filed 03/31/16 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Instructions on filing a claim:

THIS IS AN IMPORTANT LEGAL NOTICE. THE MATTERS DISCUSSED HEREIN MAY AFFECT SUBSTANTIAL LEGAL RIGHTS THAT YOU MAY HAVE. READ THIS NOTICE CAREFULLY.

FEDERAL TRADE COMMISSION UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MISSOURI CENTRAL DIVISION

DYLAN HOFFMAN, Individually, and on Behalf of All Others Similarly Situated, Plaintiff, v. WELLS FARGO & COMPANY, a Delaware Corporation, Defendant.

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

CHAPTER 36. MEDICAID FRAUD PREVENTION SUBCHAPTER A. GENERAL PROVISIONS

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) ) ) ) ) CLASS ACTION


IF YOU RENTED PUBLIC HOUSING OWNED BY THE VANCOUVER HOUSING AUTHORITY, A CLASS ACTION LAWSUIT MAY AFFECT YOUR RIGHTS

STATE OF MINNESOTA IN SUPREME COURT NO. C PETITION OF MINNESOTA STATE BAR ASSOCIATION

Case: 1:18-cv Document #: 1 Filed: 07/17/18 Page 1 of 6 PageID #:1

Transcription:

Electronically Served 9/8/2015 9:44:20 AM Hennepin County, MN STATE OF MINNESOTA COUNTY OF HENNEPIN DISTRICT COURT FOURTH JUDICIAL DISTRICT Tony Webster, v. Plaintiff, The City of Bloomington, Case Type: Other Civil Court File No.: 27-CV-15-10552 Judge: Hon. Laurie Miller Defendant. PLAINTIFF S INITIAL DISCLOSURES In compliance with Rule 26.01 of the Minnesota Rules of Civil Procedure, Plaintiff Tony Webster ( Webster ) submits, through his attorneys, the following Initial Disclosures. This Disclosure is based on the information and knowledge currently and reasonably available to Plaintiff. Plaintiff reserves the right to modify, amend, or supplement this Initial Disclosure as necessary. A. The name, and if known, the address and telephone number of each individual likely to have discoverable information along with the subjects of that information that the disclosing parties may use to support their claims or defenses, unless the use would be solely for impeachment: Without waiving its right to supplement this disclosure during discovery, Plaintiff states that the following people are likely to have discoverable information that he may use to support his claims and defenses:

Name Tony Webster Contact through counsel. Sandra Johnson City Attorney, City of Bloomington Janet Lewis City Clerk, City of Bloomington (952) 563-4989 Ann Kaul Associate City Attorney, City of Bloomington phone number unknown Anna Sullivan Office Manager/Paralegal, Bloomington City Attorney s Office (952) 563-8515 Mark Bernhardson Former City Manager, City of Bloomington Current Address and phone number unknown Last known contact: 1800 West Old Shakopee Road, (952) 563-8780 Subjects of Information Knowledge of his requests under the Minnesota Government Data Practices Act ( Webster s Request ); the City s response to Webster s Request; the City s violations Practices Act; the City s public statements about Webster Requests. City s response to Webster s request and the City s violations of the Minnesota Government Data 2

Jamie Verbrugge City Manager, City of Bloomington (952) 563-8780 Gene Winstead Mayor, City of Bloomington 9632 Xerxes Road, Bloomington, MN 55431 (952) 888-1258 Jeff Potts Chief of Police, Bloomington Police Department (952) 563-4900 All individuals identified in the documents produced by the parties in this matter. All other experts identified by the parties. Webster s request. Unknown at this time. Generally, the parties claims and defenses. Unknown at this time. Plaintiff reserves the right to call at trial all witnesses disclosed by Defendant in their Rule 26 disclosures and all witnesses that Plaintiff determines in discovery are supporting of his claims or defenses. As the Plaintiff s investigation continues, Plaintiff reserves the right to supplement this disclosure and name additional witnesses in the event such witnesses become known. B. A copy, or a description by category and location, of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment. Without waiving its right to supplement this disclosure during discovery, the Plaintiff states that such documents include: 3

1. Webster s December 23, 2014 Request. Maslon LLP, Minneapolis, MN 55402-4140, also attached as Exhibit A to Plaintiff s Complaint. 2. Communications between Plaintiff and the City regarding Webster s December 23, 2014 Request. Maslon LLP, Minneapolis, MN 55402-4140. 3. Copies of the select number of documents and data that Plaintiff was allowed to inspect and print during his designated inspections of City documents. Maslon LLP, Minneapolis, MN 55402-4140. Plaintiff reserves the right to supplement this disclosure with any information that is discovered, or to the extent necessary to meet or rebut any disputes of material facts not presently know to him or that arise in the future. C. A computation of each category of damages claimed by the disclosing party, who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered. Without waiving its right to supplement this disclosure during discovery, the Plaintiff states: Damages known to date are those asserted and detailed in Plaintiff s Complaint, including compensatory damages, in addition to any damages allowed by law, including without limitation exemplary damages, punitive damages, civil penalties, and fees, costs, and disbursements, including reasonable attorneys fees costs and expenses incurred in this lawsuit as provided by the Minnesota Government Data Practices Act and Minnesota law; permanent or temporary injunctive relief and declaratory relief; and other, further, or different relief as the Court deems just and reasonable. 4

D. For inspection and copying as under Rule 34, any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgments. Plaintiff is not aware of any insurance agreement that covers the damages alleged. Plaintiff expressly reserves that right to supplement and add to the information identified on this disclosure as this case progresses and discovery is undertaken. Dated: September 8, 2015 MASLON LLP By: s/ E. Casey Beckett Julian C. Zebot (#330644) E. Casey Beckett (#388214) Emma Greenman (#390252) 3300 Wells Fargo Center 90 South Seventh Street Minneapolis, MN 55402-4140 P: (612) 672-8200 F: (612) 672-8397 julian.zebot@maslon.com casey.beckett@maslon.com emma.greenman@maslon.com Paul Godfread (#389316) GODFREAD LAW FIRM 6043 Hudson Road, Suite 305 Woodbury, MN 55125 P: (612) 284-7325 F: (612) 465-3609 paul@godfreadlaw.com Attorneys for Plaintiff Tony Webster 5