case 5:13-cv-00112-mtt document 39-1 filed 11/22/13 page 1 ... · case 5:13-cv-00112-mtt document...

IN 1 UNITED STATES DISTRICT CO..TFOR THE MIDDLE DISTRICT OF GEORGIA

MACONDIVISION

Edward. Lamar Bloodworth

V.

Plaintiff,Civil Action No.: 5:13cv112 (MTT)

United States of America, Federal

Protective Services, Eighteen UnknownFederal Protective Service Agents of theFederal Protective Service sued intheir individual capacities

Defendant(s).

DKFKNDANT'S INITIALDISCLOSURES

COMES NOW the Defendant, by and through the United States Attorney for the Middle

District of Georgia, and for its initial disclosures pursuant to Fed. R. Civ. P. 26, states as follows:

A. Disclosures Pursuant to FRCP26 a 1 A i:

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, unless the use would be solely for impeachment.

The following individuals are likely to have discoverable information that Defendant may

use to support its defenses. While these individuals may have discoverable information,

Defendant makes no representation as to its intent to rely on this information in the defense of

this action. Further, Defendant has not yet determined the witnesses to be called in defense of

this matter, and will make those disclosures at a future time, in keeping with the Court's

scheduling order.

Case 5:13-cv-00112-MTT Document 39-1 Filed 11/22/13 of 6

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SWall

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EXHIBIT "A"

SWall

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1. David Picciolo, In..ctor, FPS, Region 4 —180 Spring Strei SW, Atlanta, GA 30303,

404-893-1572 —Inspector assigned to Immigration Court Building

2. Anthony T. Leaphart, Inspector, FPS, Region 4 —180 Spring Street, SW, Atlanta, GA

30303, 404-893-1587 —Contracting Officer's Representative on the Paragon Protective

Security Officer (PSO) Contract in Atlanta

3. Vernon L. Fields, Contract Manager, State of Georgia, Paragon Systems, Inc. —650

Hamilton Avenue, Suite J, Atlanta, GA, 30312, 404-622-8597 —Contract Manager for

Paragon Systems

4. Katrina Hill (formerly Mitchell), Paragon Protective Security Officer, Inc. —650

Hamilton Avenue, Suite J, Atlanta, GA, 30312, 404-622-8597 —PSO on duty May 25

and September 14, 2011.

5. Anthony Settle, Immigration Enforcement Agent, Immigration Custom Enforcement—

180 Spring Street, SW, Atlanta, GA 30303, 404-893-1262 —Assisted with removal of

Mr. Bloodworth from court room area

6. Jamie S olios e, Senior Immigration Enforcement Agent, Immigration Custom

Enforcement —180 Spring Street, SW, Atlanta, GA 30303 —removed Mr. Bloodworth

from court room area

7. J. McMillan, Irrunigration Enforcement Agent, Immigration Custom Enforcement —180

Spring Street, SW, Atlanta, GA 30303, 404-893-1262 —escorted Mr. Bloodworth out of

the building on May 25, 2011.


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B. Disclosure. arsuantto FRCP26 a 1 ii

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, unless the use would be solely for impeachment.

Defendant is in possession of the following categories of documents that it may use in

support of its defenses. Please note that Defendant's investigation and case preparation are on-

going, and that Defendant therefore reserves its right to use any relevant documents subsequently

obtained or prepared. Further, Defendant makes no representations as to its intent to rely upon

any of these disclosed documents in the defense of this action, and will make those disclosures in

keeping with the Court's scheduling order.

Defendant believes Plaintiff is in possession of all items listed herein. However, in the

event Plaintiff is not and ifPlaintiff will notify Defendant of such, Defendant will make available

those non-privileged, relevant documents that are in its possession, custody or control, and that

tend to support Defendant's positions in this case.

1. Standard Form 95-Claim;

2. Letter of Denial of Claim dated April 8, 2013;

3. Documents, such as agreements and contracts, that would show whether certain

persons were employees of the United States or an independent contractor;

4. Any notes, letters, or other documents that Plaintiff did or attempted to pass to his

wife during immiy ation proceedings;


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5. Any notes, mals, memoranda, letters or other docu nts written by Plaintiff or

his wife in relation to the claims stated in the Complaint;

6. Department of Homeland Security, US Immigration and Customs Enforcement,

Officer's Operation Log for May 21, 2011 and September 14, 2011;

7. Department of Homeland Security, US Immigration and Customs Enforcement,

Ofhce of Detention and Removal Operations memo dated May 25, 2011 by Jamie

Sollose regarding Plaintiff s removal from Judge Cassidy's court room;

8. All documents, photographs, and Wngs identified in Plaintiff s initial disclosures;

9. All discoverable documents that are not currently known, but that may be

discovered over the course of the subject litigation.

C. Disclosures Pursuant toFRCP26 a 1 iii:

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.

Defendant is not claiming any damages at this time.

D. Disclosures Pursuant to FRCP 26 a 1 iv:

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


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possible judgme~ a the action or to indemnify or rein. rse for payments

made to satisfy the judgment.

Defendant is not so insured

This 9 day of August, 2013.

Respectfully submitted,

MICHAELJ. MOORETED STATES ATTO

BY.SHEETUL S. WALLASSISTANTUNITED STATES ATTORNEYGeorgia Bar No. 734724

United States Attorney's Office

P. O. Box 2568

Columbus, GA 31902

Phone: (706) 649-7700


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CERTIFICATEOF SERVICE

I hereby certify that I have this date mailed a true and correct copy of the within and

foregoing Defendant's Initial Disclosures, by depositing same in the United States Mail, postage

prepaid, and addressed as follows:

Edward Lamar BloodworthP.O. Box 27193

Macon, Georgia 31221

This 9 day of August, 2013.

Respectfully submitted,

MICHAELJ. MOOREITED STATES ATTORNEY

BY:SHEETUL S. WALLASSISTANTUNITED STATES ATTORNEYGeorgia Bar No. 734724

Attorney for Defendant


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