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UNITED STATES DISTRICT COURT

[courtDistrict], [courtDivision]

[plfName]	)	Case No (LT)
Plaintiff	)	[caseNo]
)
v.	)
)
[defName],	)
Defendant	)

PLAINTIFF’S INITIAL DISCLOSURES

Plaintiff, [plfName], on this [D] day of [MMM] [YYYY], hereby submits his Initial Disclosures pursuant to Rule 26(a)(1) Fed. R. Civ. P..

Table of Contents:

Disclaimer	2nd Page
‘People of Interest’	3rd Page
‘Evidence’	4th Page
‘Computation of Damages’	4th Page
‘Insurance/Indemnity’	6th Page

DISCLAIMER

These Initial Disclosures are made by Plaintiff without waiving - but expressly reserving - the right to object to the competence, relevance, materiality, privilege, and admissibility of the information and/or materials contained herein.

Plaintiff also reserves the right to – at any time – revise, supplement, correct, add to, or clarify these Initial Disclosures on the basis of:

newly-acquired documents/information; or

documents/information that otherwise come to the attention of Plaintiff after service of these Initial Disclosures (whether via discovery herein or otherwise); or

a requirement from the Fed. R. Civ. P.; or

a requirement from USFLMD’s Local Rules of Court; or

any other reason.

Abbreviations:

FCHR	-	Florida Commission on Human Relations
USFLMD	-	US District Court, Florida, Middle District
USFLND	-	US District Court, Florida, Northern District
USFLSD	-	US District Court, Florida, Southern District

I.	Rule 26(a)(1)(i)	People of Interest

001
N:	[001nm]	Subject
A:	[001addy]	[001subj]
P:	[001phn]

002
N:	[002nm]	Subject
A:	[002addy]	[002subj]
P:	[002phn]

003
N:	[003nm]	Subject
A:	[003addy]	[003subj]
P:	[003phn]

Impeachment Witnesses to be named later

II.	Rule 26(a)(1)(ii)	Evidence

Information submitted to the FCHR regarding this dispute

Information received from the FCHR regarding this dispute

Publicly available information

Freely available information

III.	Rule 26(a)(1)(iii)	Computation of Damages

Disparate Wages

Year	Computation	Amount
20AA:	(PW – AW) + AccInt	tbd
20AB:	(PW – AW) + AccInt	tbd

Total ≈ tbd

Backpay

Year	Computation	Amount
20AB:	(PW – 0) + AccInt	tbd
20AC:	(PW – 0) + AccInt	tbd
20AD:	(PW – 0) + AccInt	tbd

Total ≈ tbd

Front Pay

5-Year Estimate

IF	Computation	Amount
EI>PW:	0	tbd
EI≤PW:	(PW – EI)	tbd

Total ≈ tbd

Punitive Damages*

Deterrent for Defendant’s unlawful conduct

Amount ≈ tbd

Total ≈ tbd

Compensatory Damages**

Medical Bill

Amount ≈ [$#,###]

Pain & Suffering

Amount ≈ tbd

Total ≈ [$#,###] + tbd

Legal Fees

Attorney Fees

monies paid to attorneys/legal professionals in regards to this dispute

Amount ≈ tbd

Litigation Costs

costs in connection to this civil dispute

Amount ≈ tbd

Total ≈ tbd

Grand Total

Grand Total = (1)+(2)+(3)+(4)+(5)+(6)

Grand Total ≈ (tbd)+(tbd)+(tbd)+(tbd)+(tbd)+($8,000+tbd)

Grand Total ≈ $8,000 + tbd

Definitions

AccInt	=	Accrued Interest
the interest that would have accrued from the first payment date through case disposition.
AW	=	Actual Wages
the income (salary, bonus, etc.) that Defendant actually paid Plaintiff
EI	=	Earned Income
the amount of money Plaintiff earns (future years)
gf	=	Growth Factor
the annual increment to wages (eg, salary increases, etc.)
PW	=	Proper Wages
the income (salary, bonus, etc.) Plaintiff would have received if not for Defendant’s discrimination
tbd	=	“To Be Determined”
The value is not yet known. In some instances, the inputs and/or dates are yet to be known. In other instances (eg “(3)”), the inputs need to be measured (eg, “EI”).

* punitive damages will be based on discovery/trial

** compensatory damages will be based on discovery/trial

IV.	Rule 26(a)(1)(iv)	Insurance/Indemnity

Plaintiff does not have any insurance to cover him against losses from Defendant’s discriminatory conduct.

CERTIFICATE OF COMPLIANCE

I certify that the size and style of type used in this document is Times New Roman 14-point Font (caption) and Courier New 12-point Font (contents); thus complying with the font requirements of Local Rule 1.05(a).

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [D] day of [MMM] [YYYY], I electronically filed the foregoing with the Clerk of Courts by using its online filing page. I also emailed it to the attached service list.

/s/ [plfName]

[plfName], Plaintiff

[plfAddy]

P: [plfPhn]

E: [plfEml]

W: TextBookDiscrimination.com

Endnotes:

How-To Guide: (interactive)

TextBookDiscrimination.com/Guides/InitialDisclosures.html

SERVICE LIST

[defAtt], Esquire ([barNum]) E: [defEml] P: [defPhn] (defendant’s trial lawyers)

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