MCLAUGHLIN v. PHILADELPHIA PHILLIES

Filing 9

Disclosure with Certificate of Service by KIMBERLY MCLAUGHLIN.(LUONGO, MICHAEL)

MCLAUGHLIN v. PHILADELPHIA PHILLIES

Doc. 9

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ________________________________________________________________________ KIMBERLY MCLAUGHLIN, : : CIVIL ACTION Plaintiff, : : v. : : NO. 04-CV-6003 PHILADELPHIA PHILLIES : a/k/a/ THE PHILLIES, : : Defendant. : ________________________________________________________________________ PLAINTIFF KIMBERLY MCLAUGHLIN'S RULE 26(a)(1) INITIAL DISCLOSURES Pursuant to Fed. R.C.P. 26(a)(1), plaintiff Kimberly McLaughlin hereby provides the following initial disclosures: Plaintiff, Kimberly McLaughlin, reserves the right to claim applicable objections to production of witnesses, documents and information, and makes this disclosure without waiving said right. Plaintiff further reserves the right to supplement or amend these disclosures based on continuing investigation, if applicable. A. WITNESSES Kimberly McLaughlin 241 Leon Avenue Norwood, PA 19074 Eileen McLaughlin 241 Leon Avenue Norwood, PA 19074 Lizzie DiPrimo 1825 Wolfe Street Philadelphia, PA 19145

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Ray Solley Security Officer 2247 South Lambert Street Philadelphia, PA 19145 The following witnesses are employees of defendant The Phillies: Anne Wise Section Supervisor Bernadette Mansi Secretary, Stadium Operations Eric Tobin Director, Event Operations Louie Mastrippolito Head of Security Dawn McClain Game-day employee Cathy Stamus Security/Game-day employee Bonnie Eastlock Game-day employee B. EXHIBITS The following documents are in possession of plaintiff: Log of events of Kimberly McLaughlin and Eileen McLaughlin. The following documents are in possession of defendant: Employment records for Ray Solley; including any investigation or background check performed prior to hiring and documents regarding his termination of employment Employment records for Kimberly McLaughlin and Eileen McLaughlin. All documentation and records of defendant The Phillies relating to complaints of sexual harassment by any agent or employee of The Phillies, including Ray Solley, from October 2000 to October 2004.

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All records of the security department of The Phillies, including documents prepared or maintained by Louis Mastrippolito, head of security, relating to the incidents set forth in plaintiff's complaint. Map of the seating sections of Veterans' Stadium. Policies and procedures of defendant The Phillies relating to sexual harassment as of the 2003 season, as well as the 2004 and 2005 seasons. Employee handbook of defendant The Phillies for the 2003 season as well as the 2004 and 2005 seasons.

C.

DAMAGES Plaintiff seeks compensatory damages for lost wages, emotional pain and suffering, inconvenience, mental anguish as well as punitive damages.

D. N/A

INSURANCE

Respectfully submitted,

Date: September 21, 2005

By:

s/Michael R. Luongo Michael R. Luongo Attorney I.D. No. 63014 324 Chestnut Street, Suite 1108 Philadelphia, PA 19106 215-829-0916 Attorney for plaintiff Kimberly McLaughlin

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CERTIFICATE OF SERVICE

I, Michael R. Luongo, hereby certify that on this date I have served a true and correct copy of the foregoing plaintiff's Initial Disclosures upon defendant by first class US mail upon the following: Richard L. Strouse Ballard Spahr 1735 Market Street 51st Floor Philadelphia, PA 19103

Date: September 21, 2005

___ s/Michael R. Luongo___ Michael R. Luongo

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