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CARFAGNO Et Al v. THE PHILLIES - Document No. 6
CARFAGNO Et Al v. THE PHILLIES - Document No. 6
6
Case 2:06-cv-03737-LDD Document 6 Filed 09/21/2006 Page 1 of 14
MARK A. CARFAGNO, :
2732 Plover Street :
Philadelphia, PA 19153 :
:
and : CIVIL ACTION
:
KATHERINE M. CARFAGNO :
2732 Plover Street : NO. 06-3737
Philadelphia, PA 19153 :
Plaintiffs, :
:
v. : JURY TRIAL DEMANDED
:
THE PHILLIES, :
One Citizens Bank Way, :
Philadelphia, PA 19148 :
Defendant.
Mark A. and Katherine M. Carfagno herein submit their required initial disclosures.
addition to Plaintiffs, are likely to have information that Plaintiffs may use to support
their claims or defenses. Plaintiffs reserve the right to supplement this witness list
with the names of additional witnesses at such time as Plaintiffs learn such
information.
1. Greg Winter
Dockets.Justia.com
Case 2:06-cv-03737-LDD Document 6 Filed 09/21/2006 Page 2 of 14
2. Fran Dunn
and treatment of Plaintiff Mark Carfagno for depression and anxiety, and resultant
additional medical problems, and Plaintiff Mark Carfagno’s fitness to return to work
and treatment of Plaintiff Mark Carfagno for major depressive disorder and panic
disorder and his fitness to return to work in 2004 through the present.
Dr. Shrom is likely to have discoverable information regarding the effect that
Telephone: 610-296-6303
Mr. Hall is likely to have discoverable information regarding the effect on Mr.
Mr. Carfagno’s employment, the job responsibilities of the grounds crew, and related
matters.
Carfagno’s complaints about Mr. Boekholder and the circumstances surrounding the
Mr. Carfagno’s employment, the job responsibilities of the grounds crew, and related
matters.
Carfagno’s complaints about Mr. Boekholder and the circumstances surrounding the
things listed below that are in the custody of Plaintiffs that Plaintiffs may use to
support their claims or defenses. Plaintiffs reserve the right to supplement this list at
with the Philadelphia Commission on Human Relations and the Equal Employment
Opportunity Commission.
and treatment.
compensation.
unemployment compensation.
Phillies.
10. DVDs, books and other promotional media in which Plaintiff Mark
Carfagno appears which was made available to the public by Defendant or with
Montgomery.
C. Computation of Damages
Plaintiffs are seeking damages for back pay and benefits, front pay and
$100,000 but they are currently in the process of locating an expert to more
D. Insurance Agreements.
Not applicable.
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Plaintiffs’ Rule 26(a) Initial Disclosures
was filed electronically and is available for viewing and downloading from the ECF
system of the United States District Court for the Eastern District of Pennsylvania,
and that I served the same on this day upon the following via hand delivery: