IN THE SUPERIOR COURT OF THE STATE OF DELAWARE NEW CASTLE COUNTY

LAWRENCE MILLS

705 Winhall Way

Silver Spring, MD 20904

Plaintiff

vs.

PIVOT OCCUPATIONAL HEALTH

914 Justison St, Wilmington,

Delaware, 19801

and

PIVOT PHYSICAL THERAPY

1214 Beaver Brook Plaza Ste. A,

New Castle, DE 19720

and

OSBORNE SOCIAL VENTURES, LLC

251 Little Falls Drive

Wilmington, DE, 19807

and

KRISTEN CRISPIN

Individually and as an Agent of the

Co-Defendant Pivot Occupational Health

26 Colesbery Dr

Wilmington Manor, DE 19720

and

OFFICER DAVID WINCH

In his Individual Capacity

2162 New Castle Ave,

New Castle, DE 19720

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* CIVIL ACTION NO:

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PLAINTIFF’S FIRST SET OF INTERROGATORIES

TO: PIVOT PHYSICAL THERAPY

Plaintiff Lawrence Mills by himself and on his own behalf, hereby demands that Pivot Physical Therapy provide the following answers to interrogatories within (30) days of service hereof and in compliance with Del. R. Civ. P. Super. Ct. 33, to the offices of Pivot Occupational Health, 1214 Beaver Brook Plaza Ste. A, New Castle, DE 19720.

INSTRUCTIONS AND DEFINITIONS

1. These Interrogatories constitute a continuing request for information responsive thereto.
2. Stipulated below all interrogatories shall pertain to the events of [insert date] involving Plaintiff (the “occurrence” or “incident”). The occurrence begins with Dominique Liverpool playing craps and being threatened with being shot by another individual and concluding with Liverpool being released by casino personnel.
3. Defendants shall amend or supplement a prior response if it obtains information which causes or should cause it to know that the response, though correct when made, is no longer true and that circumstances are such that a failure to amend or supplement the response will conceal facts. Defendants shall serve each such supplemental response no later than 30 days after discovery of further information.
4. Each Interrogatory should be answered upon Defendants’ entire knowledge from all sources and all information in its possession or otherwise available to it, including information from Defendants’ employees, agents, representatives, partners, or consultants and information which is known by each of them. An incomplete or evasive answer is a failure to answer.
5. Each Interrogatory shall be answered separately and fully.
6. Each Interrogatory shall be construed independently and not with reference to any other Interrogatory for the purpose of limitation.
7. If any answer is qualified, state specifically the terms of each qualification and the reasons for it. If an Interrogatory cannot be answered in full, state the part which can be answered and answer the same in full to the extent possible; state the reason(s) why the remainder cannot be answered.
8. If Defendants withhold any information called for by an Interrogatory by reason of a claim of privilege or work product, Defendants shall furnish a list setting forth as to each objection the information.
9. A request to identify a document is a request to state as applicable:
10. The date of the document;
11. The type of document;
12. The names and present addresses of the person or persons who prepared the document and of the signers and addressers of the document;
13. The name of the employer or principal whom the signers, addressers, and preparers were representing;
14. The present location of the document;
15. The name and current business and home addresses of the present custodians of the original documents, and any copies of it;
16. A summary of the contents of the documents; and
17. If the original document was destroyed, the date and reason for or circumstances under which it was destroyed.
18. A request to identify a person means to provide the following information to the extent known or ascertainable using reasonable efforts:
19. the person’s employer(s) and position with such employer(s) during the time period for which information is provided for the person in response to the Interrogatory;
20. the name, address and phone number of the person’s attorney, if the person is represented by an attorney with respect to this action; and
21. the last known or ascertainable address and phone number of the person, if the person is not represented by an attorney with respect to this action.
22. If any Interrogatory may be answered fully by a document, the document may be attached in lieu of an answer if the document is marked to refer to the Interrogatory to which it responds.

INTERROGATORIES

1. Identify whether Pivot Physical Therapy is owned by Osborne Social Ventures LLC.
2. Identify whether Pivot Occupational Health is owned by Pivot Physical Therapy.
3. Identify whether Pivot Occupational Health owns Pivot Physical Therapy.
4. Identify each of the Pivot Occupational Health employees present during the incident.
5. Identify the employment capacity (job title and general description of duties) of each Pivot Physical Therapy employee listed in interrogatory 2 above.
6. Identify each law enforcement personnel that was present.
7. State and describe in detail each document granting Pivot Physical Therapy authority to touch Lawrence Mills.
8. Describe the actions undertaken by each agent, affiliate, or employee during the incident.
9. State and describe with particularity what each Pivot Physical Therapy employee stated to or said to Lawrence Mills when they first approached him.
10. Describe the actions undertaken by law enforcement personnel to lawfully authorize interaction with Lawrence Mills.
11. Was Pivot Physical Therapy informed of Lawrence Mills alleged intoxication.
12. List all of the policies and procedures in effect at Pivot Physical Therapy including but not limited digital, hardcopy, video, audio, training sessions governing involuntary withdrawal of blood from an individual under police custody.
13. Lawrence Mills informed Kristen Crispin he was not intoxicated. Describe in detail Kristen Crispin’s reaction/response to the information.
14. Did Pivot Physical Therapy investigate of the incident, and if so, did it produce any reports of the same?
15. State and describe with particularity, revenue generated by Pivot Physical Therapy with respect to the incident.

Respectfully submitted,

/s/ Justin Mills

Dated: July 17, 2021 Lawrence J. Mills

705 Winhall Way

Silver Spring, MD 20904

Telephone: (240) 338-4999

Plaintiff

CERTIFICATE OF SERVICE

I HEREBY CERTIFY on this 1^st day of July, 2021 that a copy of Plaintiff’s Motion for Authorization to File Electronically was served via email to the Defendants at:

Gordon, Fournaris & Marshall Dennehey Warner

Mammarella, P.A.  Coleman & Goggin

William M. Kelleher, Esq. (#003645) Aaron E. Moore (#6739)

Phillip A. Giordano, Esq. (#005756) 1007 N. Orange Street, Suite 600

1925 Lovering Avenue P.O. Box 8888 

Wilmington, DE 19806 Wilmington, DE 19899

wkelleher@gfmlaw.com  aemoore@mdwcg.com

pgiordano@gfmlaw.com

Kristen Crispin

933 Gray Street

New Castle, DE 19720

kristencrispin14@gmail.com

/s/ Justin Mills

          Lawrence J. Mills

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