PLAINTIFF’S INITIAL DISCLOSURES PURSUANT TO RULE 26(a)

Boyd Johnson

634 NW 44th Terrace

Deerfield Beach, FL 33442

(305) 781-7431

boyd5307@gmail.com

 

Plaintiff in pro per

 

in the united states district court

for the southern district of florida

fort lauderdale division

 

boyd johnson,

Plaintiff,

vs.

publix super markets, inc., irby, mark r., phillips, david p. metz, merriann m., jones, sr., randall t.,

Defendants

 Case No.: 0-22-CV-60884-KMM

PLAINTIFF’S INITIAL DISCLOSURES PURSUANT TO RULE 26(a)

 

 

COMES NOW Boyd Johnson, Plaintiff, pursuant to Rule 26(a) of the Federal Rules of Civil Procedure, and makes the following disclosures:

  1. 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 party may use to support its claims or defenses:
  2. Plaintiff Boyd Johnson

634 NW 44th Terrace

Deerfield beach, FL 33442

(305) 781-7431

He has personal knowledge of the events that occurred on the day he was subjected to discrimination by employees and/or agents of Publix Super Markets, Inc.

  1. Any and all individuals and/or entities listed in Defendants’ Initial Disclosures.
  2. 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:
  3. Any and all documents, electronically stored information and/or tangible things listed in Defendants’ Initial Disclosures.
  4. 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:
  5. Amount to be determined by a jury for the causes of action in Plaintiff’s Complaint;
  6. Pre-judgment and post-judgment interests; and
  7. All costs and expenses of this action.
  8. 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 judgment:

Under information and belief, Plaintiff forms the opinion that there is no insurance available to satisfy all or part of a possible judgment.

  1. Pursuant to Rule 26(a)(2), Plaintiff submits that he has not determined the need for and/or identified an expert witness but will supplement this response in accordance with the rules.
  2. Plaintiff reserves the right to supplement or otherwise amend these disclosures as their investigation of and discovery in this matter continues.

 

Dated this ____ day of June, 2022.

 

Respectfully Submitted,

 

___________________________________

Boyd Johnson,

Plaintiff in pro per

 

 

VERIFICATION

I, Boyd Johnson, being duly sworn depose and say that I have read the foregoing Initial Disclosures and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.

 

_________________________________

(Sign in the presence of a Notary Public)

 

Sworn to and subscribed before me this ___ day of June, 2022.

______________________________

Notary Public

________________________________________

(Printed name of Notary Public)

My Commission Expires: ____________________