Fill and Sign the Order Plaintiffs Motion to Dismiss for Hedgepeth Et Al V Form

IN THE UNITED STATES DISTRICT COURT FOR THE________________________ OF ALABAMA ___________________ DIVISION _______________ **Plaintiff,**vs. * CIVIL ACTION NUMBER*_________________________ * _________________________________, *_____________, et al., **Defendants.** INITIAL DISCLOSURES OF PLAINTIFF Pursuant to the provisions of Fed.R.Civ.P. 26, Plaintiff provides the following initial disclosures:(1)Individuals that are likely to have discoverable information include, but maynot be limited to, the following:(1)Mr. ______ is expected to have factual information.(2)Ms. ______ is Mr. ________ spouse, and would have factual information.(3)Mr. _____ is or was the agent for ________________ and/or the other Defendants that sold the subject policy to Mr. ______, and is expected to have factual informationAlso, Plaintiff may have spoken with friends, his children, or various other people after he discovered problems with his policy. These people would only know what they were told by Plaintiff; they would not have information relevant to the facts involved in the actual sale and representations relating to the Plaintiffs policy. The corporate Defendant and/or other individuals employed with or agents of the Defendant may have factual information. Plaintiff also anticipates expert testimony, but is not certain at this time who the expert(s) will be due to the infancy of this matter. Plaintiff will comply with Fed.R.Civ.P. 26(a)(2).(2)All documents, data, compilations, and tangible things in the possession, custody, or control of Plaintiffs that are relevant to disputed facts alleged with particularity in the pleadings:See attached documents: Bates numbered 1- 58.(3)Provide computation of any category of damages claimed by the disclosingparty.Other than the claims involving non-economic loss (mental anguish, anxiety, stress, emotional suffering, etc.), Plaintiff claims loss of the amount of money paid in premiums to the Defendant for the subject policy; loss of increased and further payments to be made in the future; has lost the permanent life insurance and the value in that policy that he gave up/canceled in order to purchase this policy in 1994; has lost the ability to purchase other life insurance at the same cost as this policy or the costs in 1994 of actual permanent insurance.(4)Insurance Agreement.N/A. JOHN DOE & ASSOCIATES, P.C.Attorneys for PlaintiffPost Office Drawer ____Mobile, Alabama _____(334) ________BY:______________________________________AttorneyNumber CERTIFICATE OF SERVICE I do hereby certify that I have on this 15th day of October, 1999, served a copy of the foregoing pleading on all counsel to this proceeding by mailing the same to each by First Class United States Mail, properly addressed and postage prepaid.Defense counsel_____________________________ Attorney