IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF SOUTH CAROLINA

CHARLESTON DIVISION

CASE NUMBER: 

ADELAIDE DIXON, INDIVIDUALLY

AND ON BEHALF OF ALL OTHERS 

SIMILARLY SITUATED

Plaintiff,

v.

UNIVERSITY OF MIAMI

Defendants.

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PLAINTIFF’S RESPONSE TO

LOCAL RULE 26.01

INTERROGATORIES

Pursuant to Local Rule 26.01, Plaintiff submits the following responses to 

Interrogatories:

A. State the full name, address, and telephone number of all persons or legal entities

who may have a subrogation interest in each claim and state the basis and extent of

that interest.

Answer

None known.

B. As to each claim, state whether it should be tried jury or nonjury and why.

Answer

Plaintiff’s claims for breach of contract an unjust enrichment present questions of fact which 

should be tried by a jury. The question of whether Plaintiff’s proposed class should be certified 

is a question of law to be decided by the Court.

C. State whether the party submitting these responses is a publically-owned company

and separately identify (1) any parent corporation and any publically held

corporation owning ten percent (10%) or more of the party’s stock; (2) each

publically-owned company of which it is a parent; and (3) each publically-owned

company in which the party owns ten percent (10%) or more of the outstanding

shares.

FY%++

Case 1:20-cv-22594-RNS Document 2 Entered on FLSD Docket 04/09/2020 Page 1 of 3
Answer 

Plaintiff is a private individual. 

D. State the basis for asserting the claim in the division in which it was filed (or the 

basis of any challenge to the appropriateness of the division). See Local Civ. Rule 

3.01 (D.S.C.). 

Answer 

Plaintiff alleges that the contract which is the subject of this action was entered in Charleston 

County, South Carolina. Moreover, the Defendant does business in Charleston County, South 

Carolina, including but not limited to procuring the contract, the breach of which is the subject of 

this action. Therefore, venue is proper in the Charleston Division pursuant to Local Rule 

3.01(A)(1). 

E. Is this action related in whole or in part to any other matter filed in this district, 

whether civil or criminal? If so, provide (1) a short caption and the full case number 

of the related action; (2) an explanation of how the matters are related; and (3) a 

statement of the status of the related action. Counsel should disclose any cases that 

may be related regardless of whether they are still pending. Whether cases are 

related such that they should be assigned to a single judge will be determined by the 

clerk of court based on a determination of whether the cases arise from the same or 

identical transactions, happenings, or events; involve the identical parties or 

property; or for any other reason would entail substantial duplication of labor if 

heard by different judges. 

Answer 

No. 

[Signatures on Following Page] 

Case 1:20-cv-22594-RNS Document 2 Entered on FLSD Docket 04/09/2020 Page 2 of 3
Respectfully Submitted, 

ANASTOPOULO LAW FIRM, LLC 

BY __/s/ Eric M. Poulin _ 

Eric M. Poulin 

Fed ID Number: 11251 

Roy T. Willey, IV 

Fed ID Number: 11664 

32 Ann Street 

Charleston, SC 29403 

(843) 614-8888

ATTORNEYS FOR PLAINTIFF 

Charleston, South Carolina 

April 8, 2020 

Case 1:20-cv-22594-RNS Document 2 Entered on FLSD Docket 04/09/2020 Page 3 of 3