mandatory disclosures

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

In accordance with Rule 26(a)(1) of the Federal Rules of Civil Procedure, Plaintiff, Chelsa S. Brown, respectfully makes her mandatory disclosures as follows:

1. Witnesses

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.

RESPONSE:

Persons likely to have discoverable information may include, but may not be limited to, the following:

• Chelsa S. Brown

6201 Chapel Hill Blvd, #116,

Plano, Texas 75093

Plaintiff

• Terry Brown

Operations Manager

c/o Arthur V. Lambert and Brent Sedge

Fisher & Phillips LLP

500 North Akard, Suite 3550

Dallas, TX 75201

Reny’s Operations Manager

• Sheila Bunton

Bill Review Manager

c/o Arthur V. Lambert and Brent Sedge

Fisher & Phillips LLP

500 North Akard, Suite 3550

Dallas, TX 75201

Reny’s Bill Review Manager

• Christina Benjamin (formerly Christina Hartwell)

c/o Arthur V. Lambert and Brent Sedge

Fisher & Phillips LLP

500 North Akard, Suite 3550

Dallas, TX 75201

Reny’s Senior Accountant/Human Resources/HIPAA Privacy Officer.

• Any and all of Plaintiff’s health care providers, including but may not be limited to:

• Jeffery Komenda, MD.

Family Medicine at Willow Bend

5944 West Parker Road, Suite 100

Plano, TX 75093

972-608-1868

Jeffery Komenda, M.D., and any and all other health care providers associated with Jeffery Komenda, M.D., involved in the examination, diagnosis, care, or treatment of Plaintiff.

Custodian of records for Howard. K. Wilson, M.D.

• Ronald Blake Tanaka, MD

Texas Health Resources

Plano Emergency Department

Ronald Blake Tanaka, M.D., and any and all other health care providers associated with Ronald Blake Tanaka, M.D., involved in the examination, diagnosis, care, or treatment of Plaintiff.

• Documents

A copy of, or a description by category and location of, all documents, electronically stored information, 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.

RESPONSE:

Plaintiff references any and all documents produced or to be produced by Defendant.

Other than documents already produced, Plaintiff is providing certain additional documents to Defendant with this disclosure.

Plaintiff has produced any and all documents within Plaintiff’s immediate possession, except any and all medical records Plaintiff has obtained which are voluminous and are available for inspection and copying by Defendant at a mutually agreeable date and time.

Discovery continues and subsequent relevant documents may be produced by Plaintiff, Defendant, or both.

Plaintiff requests copies of any and all relevant documents or medical records Defendant has in its possession or has obtained by subpoena/authorization/voluntary production.

• Computation of Damages

A computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 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.

RESPONSE:

Damages applicable under the ADA are: Back Pay

Plaintiff worked eight (8) hours per day for Defendant since November 21^st, 2019, prior to her diagnosis of COVID-19 and pneumonia, and her subsequent dismissal on December 18^th, 2020.

Unused and unpaid vacation/sick/personal time; unspecified amount at this time. Discovery continues—will supplement.

Worked over time/additional hours as required by employer; unspecified amount at this time. Discovery continues—will supplement

Plaintiff was earning $43,680/year in her employment with Defendant.

Plaintiff worked five (5) days a week from November 21^st, 2019 to December 18^th, 2020. Thus, Plaintiff would have earned $21,840 from The Reny Company during this period ($[43,680]/year divided by 12 months/year [$[3,640]/month] x 6 months = $[21,840]).

Interest on Back Pay

Interest at the highest lawful legal rate allowed by law.

Compensatory Damages (Emotional Pain, Suffering, Inconvenience, Mental Anguish, Loss of Enjoyment of Life and Other Non-Pecuniary Losses

Unliquidated—amount up to trier of fact after all evidence presented.

Pre-Judgment Interest

Interest at the highest lawful legal rate allowed by law.

Punitive Damages

Unliquidated—amount up to trier of fact after all evidence presented.

Court Costs

These costs will be the actual court costs incurred—amounts continue to accrue.

Reasonable Attorney’s Fees

Amount decided by trier of facts after all evidence presented—amounts continue to accrue.

Reasonable Expert Fees

Amount decided by trier of facts after all evidence presented.

Damages Under the 1993 Family Medical Leave Act

Wages, Salary, Employment Benefits, and Other Compensation

Wages, salary, employment benefits, and other compensation denied and lost to Plaintiff.

Interest on the Damages Set Forth Above

Amount will be calculated at the prevailing rate pursuant to the applicable provisions of the FMLA.

Liquidated Damages

Additional amount as liquidated damages equal to the sum of the amount described above calculated as described.

Equitable Relief

As may be appropriate—amounts decided by court/jury after all evidence presented.

Reasonable Fees

Amounts continue to accrue and will be decided by the trier of facts after all evidence presented.

Reasonable Expert’s Fees

Amounts continue to accrue and will be decided by the trier of fact/court after all evidence presented.

Costs of This Action

These costs will be the actual court costs incurred—amounts continue to accrue.

Damages Under the Fair Work Act 2009

Wages, Salary, Employment Benefits, and Other Compensation

Wages, salary, employment benefits, and other compensation denied and lost to Plaintiff.

Interest on the Damages Set Forth Above

Amount will be calculated at the prevailing rate pursuant to the applicable provisions of the Fair Work Act 2009.

Liquidated Damages

Additional amount as liquidated damages equal to the sum of the amount described above calculated as described.

Equitable Relief

As may be appropriate—amounts decided by court/jury after all evidence presented.

Reasonable Fees

Amounts continue to accrue and will be decided by the trier of facts after all evidence presented.

Reasonable Expert’s Fees

Amounts continue to accrue and will be decided by the trier of fact/court after all evidence presented.

Costs of This Action

These costs will be the actual court costs incurred—amounts continue to accrue.

Compensation under the Federal Civil Rights Acts of 1964

Compensatory Damages (Emotional Pain, Suffering, Inconvenience, Mental Anguish, Loss of Enjoyment of Life and Other Non-Pecuniary Losses

Unliquidated—amount up to trier of fact after all evidence presented.

Pre-Judgment Interest

Interest at the highest lawful legal rate allowed by law.

Punitive Damages

Unliquidated—amount up to trier of fact after all evidence presented.

Violation of Due Process, Equal Protection

Compensatory Damages (Emotional Pain, Suffering, Inconvenience, Mental Anguish, Loss of Enjoyment of Life and Other Non-Pecuniary Losses)

Unliquidated—amount up to trier of fact after all evidence presented.

Pre-Judgment Interest

Interest at the highest lawful legal rate allowed by law.

Punitive Damages

Unliquidated—amount up to trier of fact after all evidence presented.

Equitable Relief

As may be appropriate—amounts decided by court/jury after all evidence presented.

Reasonable Fees

Amounts continue to accrue and will be decided by the trier of facts after all evidence presented.

Compensation for defamation 28 U.S.C § 4101

Compensatory Damages (Emotional Pain, Suffering, Inconvenience, Mental Anguish, Loss of Enjoyment of Life and Other Non-Pecuniary Losses)

Unliquidated—amount up to trier of fact after all evidence presented.

Pre-Judgment Interest

Interest at the highest lawful legal rate allowed by law.

Punitive Damages

Unliquidated—amount up to trier of fact after all evidence presented.

Equitable Relief

As may be appropriate—amounts decided by court/jury after all evidence presented.

Reasonable Fees

Amounts continue to accrue and will be decided by the trier of facts after all evidence presented.

• Insurance Agreements

For inspection and copying as under Rule 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 the action or to indemnify or reimburse for payments made to satisfy the judgment.

RESPONSE:

None in Plaintiff’s possession. Plaintiff is not being sued. See Defendant’s responses for insurance applicable for Defendant.

DATED: [insert date]

Respectfully submitted,

________________________________

Chelsa Brown

6201 Chapel Hill Blv., #116

Plano, TX 75093.

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