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Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY,
Plaintiffs,
vs.
BAPTISTE & WILDER, P.C.,
ROBERT M. BAPTISTE, and
PATRICK J. SZYMANSKI,
Defendants.
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CASE NO.: 1:05CV01958
JUDGE: James Robertson
AMERICAN GUARANTEE & LIABILITY INSURANCE
COMPANY’S INITIAL DISCLOSURES
Plaintiff American Guarantee & Liability Insurance Company (“American Guarantee”)
hereby responds to the following disclosures as required by Federal Rule of Civil Procedure
26(a)(1) as follows:
(1)
The name, and if known, the address and telephone number of each
individual likely to have discoverable information that the disclosing party may use to
support its claims or defenses, unless solely for impeachment, identifying the subjects of the
information.
The following individuals may have discoverable information that American Guarantee
may use to support its claims or defenses:
•
Robert M. Baptiste – Defendant. Mr. Baptiste is expected to have knowledge of
facts relating to the litigation styled Martha J. Lockwood v. Robert M. Baptiste,
et. al., filed in the Superior Court of the District of Columbia, Case No. 040007551 (the “Underlying Litigation”).
1953856v1Page 2 Patrick J. Szymanski – Defendant. Mr. Szymanski is expected to have knowledge
of facts relating to the Underlying Litigation.
•
Martha J. Lockwood – Ms. Lockwood is expected to have knowledge of facts
relating to the Underlying Litigation.
Additionally, American Guarantee may rely on a corporate representative of American
Guarantee or its affiliates to support its claims and/or defenses relating to the coverage issues in
this action. American Guarantee reserves the right to supplement or amend this response as
discovery in this action proceeds.
(2)
A copy of, or description by category and location of, all documents, data
compilations, and tangible things that are in the possession, custody, or control of the party
and that the disclosing party may use to support its claims or defenses, unless solely for
impeachment.
At this time, American Guarantee identifies the following relevant documents, which are
located at the offices of Arnall Golden Gregory LLP, 171 17th Street, NW, Suite 2100, Atlanta,
Georgia, 30363:
•
Lawyers Professional Liability Insurance Policy issued to Baptiste & Wilder, P.C.
for the policy period of November 5, 2003 to November 5, 2004, No. LPL
4907012-1 (the “Policy”).
•
Pleadings in the Underlying Litigation and documents related thereto.
•
Correspondence between Martha J. Lockwood and Defendants.
(3)
A computation of any category of damages claimed by the disclosing party,
making available for inspection and copying as under Fed. R. Civ. P. 34 the documents or
other evidentiary material, not privileged or protected from disclosure, on which such
computation is based, including materials bearing on the nature and extent of injuries
suffered.
American Guarantee claims no damages at this time.
-21953856v1Page 3 (4)
Produce for inspection and copying as under Fed. R. Civ. P. 34 any insurance
agreement under which any person carrying on an insurance business may be liable to
satisfy part or all of a judgment which may be entered in this action or to indemnify or
reimburse for payments to satisfy the judgment.
Since the case is a declaratory judgment action, there is no insurance policy that might
pay for a judgment in this case. However, the Policy, which is the subject of this case, is in
Defendants’ possession.
This ________ day of ________________________ 2006.
Respectfully submitted,
CARR MALONEY P.C.
By:
/s/
William J. Carter, 329637
1615 L Street, N.W., Suite 500
Washington, D.C. 20036
(202) 310-5500 (phone)
(202) 310-5555 (fax)
ARNALL GOLDEN GREGORY LLP
By:
/s/
Scott F. Bertschi
Admitted Pro Hac Vice
Michelle M. Kahoiwai
Admitted Pro Hac Vice
2800 One Atlantic Center
1201 West Peachtree Street
Atlanta, Georgia 30309-3450
(404) 873-8500 (phone)
(404) 873-8501 (fax)
Attorneys for Plaintiff
-31953856v1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:05-cv-01958-JR
Document 13
Filed 01/31/2006
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY,
Plaintiffs,
vs.
BAPTISTE & WILDER, P.C.,
ROBERT M. BAPTISTE, and
PATRICK J. SZYMANSKI,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: 1:05CV01958
JUDGE: James Robertson
AMERICAN GUARANTEE & LIABILITY INSURANCE
COMPANY’S INITIAL DISCLOSURES
Plaintiff American Guarantee & Liability Insurance Company (“American Guarantee”)
hereby responds to the following disclosures as required by Federal Rule of Civil Procedure
26(a)(1) as follows:
(1)
The name, and if known, the address and telephone number of each
individual likely to have discoverable information that the disclosing party may use to
support its claims or defenses, unless solely for impeachment, identifying the subjects of the
information.
The following individuals may have discoverable information that American Guarantee
may use to support its claims or defenses:
•
Robert M. Baptiste – Defendant. Mr. Baptiste is expected to have knowledge of
facts relating to the litigation styled Martha J. Lockwood v. Robert M. Baptiste,
et. al., filed in the Superior Court of the District of Columbia, Case No. 040007551 (the “Underlying Litigation”).
1953856v1
PDF Page 3
Case 1:05-cv-01958-JR
•
Document 13
Filed 01/31/2006
Page 2 of 3
Patrick J. Szymanski – Defendant. Mr. Szymanski is expected to have knowledge
of facts relating to the Underlying Litigation.
•
Martha J. Lockwood – Ms. Lockwood is expected to have knowledge of facts
relating to the Underlying Litigation.
Additionally, American Guarantee may rely on a corporate representative of American
Guarantee or its affiliates to support its claims and/or defenses relating to the coverage issues in
this action. American Guarantee reserves the right to supplement or amend this response as
discovery in this action proceeds.
(2)
A copy of, or description by category and location of, all documents, data
compilations, and tangible things that are in the possession, custody, or control of the party
and that the disclosing party may use to support its claims or defenses, unless solely for
impeachment.
At this time, American Guarantee identifies the following relevant documents, which are
located at the offices of Arnall Golden Gregory LLP, 171 17th Street, NW, Suite 2100, Atlanta,
Georgia, 30363:
•
Lawyers Professional Liability Insurance Policy issued to Baptiste & Wilder, P.C.
for the policy period of November 5, 2003 to November 5, 2004, No. LPL
4907012-1 (the “Policy”).
•
Pleadings in the Underlying Litigation and documents related thereto.
•
Correspondence between Martha J. Lockwood and Defendants.
(3)
A computation of any category of damages claimed by the disclosing party,
making available for inspection and copying as under Fed. R. Civ. P. 34 the documents or
other evidentiary material, not privileged or protected from disclosure, on which such
computation is based, including materials bearing on the nature and extent of injuries
suffered.
American Guarantee claims no damages at this time.
-21953856v1
PDF Page 4
Case 1:05-cv-01958-JR
Document 13
Filed 01/31/2006
Page 3 of 3
(4)
Produce for inspection and copying as under Fed. R. Civ. P. 34 any insurance
agreement under which any person carrying on an insurance business may be liable to
satisfy part or all of a judgment which may be entered in this action or to indemnify or
reimburse for payments to satisfy the judgment.
Since the case is a declaratory judgment action, there is no insurance policy that might
pay for a judgment in this case. However, the Policy, which is the subject of this case, is in
Defendants’ possession.
This ________ day of ________________________ 2006.
Respectfully submitted,
CARR MALONEY P.C.
By:
/s/
William J. Carter, 329637
1615 L Street, N.W., Suite 500
Washington, D.C. 20036
(202) 310-5500 (phone)
(202) 310-5555 (fax)
ARNALL GOLDEN GREGORY LLP
By:
/s/
Scott F. Bertschi
Admitted Pro Hac Vice
Michelle M. Kahoiwai
Admitted Pro Hac Vice
2800 One Atlantic Center
1201 West Peachtree Street
Atlanta, Georgia 30309-3450
(404) 873-8500 (phone)
(404) 873-8501 (fax)
Attorneys for Plaintiff
-31953856v1
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