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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PANAMA CITY DIVISION

MARIA DOMINIQUE TURNER

n/k/a MARIA THOMPSON

Plaintiff, 

v. CASE NO.: 5:20-CV-199-MCR-MJF

LOUIS S. ROBERTS, III, Individually, and 

in his Official Capacity as 

Sheriff of Jackson County, Florida, 

and 

ZACHARY WESTER, former Deputy Sheriff, Individually

Defendants.

PLAINTIFF’S RULE 26(a)(1) INITIAL DISCLOSURES

The Plaintiff, Maria Thompson, pursuant to Federal Rule of Civil Procedure 

26(a)(1) submits the following as her initial disclosure:

I. POTENTIAL WITNESSES

1. All persons identified in the Defendants’ Rule 26 Disclosures.

2. The Plaintiff, Maria Thompson, who has knowledge about the facts 

and circumstances of the matters alleged in her Complaint. 

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3. The Defendants, Zachery Wester and Louis Roberts, III, who are 

expected to have knowledge about the matters alleged in the Complaint. 

4. April Marie Adkins aka April Marie Middleton, Hope Adkinson, 

Derek William Benefield, Benjamin Bowling, Michael Brady, Timothy Bruner, 

Joshua Clenney, James Coffelt, John Coulliette, Justin Caleb Creamer, Tyler 

Daniels, Cassandra E. Davis, Trevor Day, Richard Driggers, Maurice Elder, James 

Fears, Hansford Griffis, Kimberly Hazelwood, Tyler Land, Christopher Marr, 

Tillmon McCroan, John McCue, Teresa Odom, Cole Padgett, Lora Penn, Willie 

Pippin, John Raines, Lance Sellers, Kenneth Shaw, Jason Sherrod, Donnie Shores, 

Willie Sims, Vicki Stephens, Patrick Themar, Abdranda Ward, Darrell Watkins, 

Scotty J. Williams, Monica Willis, and Kimberly Wood who are expected to have 

knowledge about the matters alleged in the Complaint. 

5. Maria Thompson’s treating physicians, who have knowledge about 

her injuries and medical bills, and who are identified in her medical records.

6. All jail personnel who had any contact or communication with the 

Plaintiff during her incarceration, who may have knowledge about the arrest, 

detention, and prosecution of the Plaintiff. 

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7. All court personnel who had any contact or communication with the 

Plaintiff during the course of her prosecution, who may have knowledge about the 

arrest, detention, and prosecution of the Plaintiff. 

8. The Plaintiff’s criminal defense counsel, and her respective agents and 

employees, who may have knowledge about the arrest, detention and prosecution 

of the Plaintiff. The Plaintiff does not waive any privilege that exists with respect 

to her counsel, but identifies such persons solely with respect to any non-privileged 

information which they may have. 

9. Any other individual with knowledge or information that is revealed 

during the discovery process. 

10. Any expert witness(es) identified on Plaintiff’s behalf. 

11. Any expert witness identified by the Defendants.

The Plaintiff reserves the right to supplement this list as discovery proceeds

in accordance with the Federal Rules of Civil Procedure and/or this Court’s 

Scheduling Order.

II. DOCUMENTS

The Plaintiff reserves the right to raise appropriate objections to the 

production of any documents, electronically stored information, and tangible 

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things. Without waiving these objections, the Plaintiff identifies the following 

items, which may be used to support her claims.

1. Maria Thompson’s medical records, which are possessed by her 

medical providers. 

2. Maria Thompson’s medical bills, which are possessed by her medical 

providers. 

3. All records created, maintained and/or kept by the Florida Department 

of Law Enforcement that reference or relate in any manner to the acts alleged in 

the Plaintiff’s Complaint or the arrest, detention, or prosecution of the Plaintiff. 

These records contain .pdf, .mp4, .mp3, .mov, and .wav file formats. Plaintiff is 

currently compiling said records and will produce them as soon as possible. 

4. All Court records relating to the arrest, detention, or prosecution of 

the Plaintiff. Plaintiff is currently compiling said records and will produce them as 

soon as possible. 

III. DAMAGES

The Plaintiff is seeking damages for deprivation of liberty, indignity, arrest, 

detention, physical confinement, booking, arraignment, transportation while under 

arrest, loss of civil rights, compulsion, and criminal prosecution, physical injuries, 

mental and physical pain and suffering, emotional distress and anguish, 

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embarrassment, and humiliation. The Plaintiff reserves the right to supplement this 

disclosure as this case progresses and new information is discovered in accordance 

with Federal Rules of Civil Procedure and/or this Court’s Scheduling Order.

IV. INSURANCE

Not applicable to the Plaintiff.

Respectfully submitted,

/s/ J. Ryan Will_______________

J. RYAN WILL 

Florida Bar No. 0024122

Morgan & Morgan, P.A.

444 Seabreeze Boulevard, Suite 100

Daytona Beach, FL 32118

Telephone: (386) 947-9959

Facsimile: (859) 367-6146

Email: rwill@forthepeople.com

Counsel for Plaintiff

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CERTIFICATE OF SERVICE

I certify that a copy of the foregoing has been served via electronic mail on 

December 10, 2020 to the parties: 

Riley Landy

Joe Longfellow

Andrews, Crabtree, 

Knox & Longfellow, LLP

1558-1 Village Square Blvd.

Tallahassee, FL 32309

rlandy@andrewscrabtree.com

jlongfellow@andrewscrabtree.com

Counsel for Defendant,

Zachary Wester

Alyssa M. Yarbrough

William G. Warner

Warner Law Firm, P.A.

P.O. Box 1820

Panama City, FL 32402

alyssayarbrough@warnerlaw.us

billwarner@warnerlaw.us

Counsel for Defendant,

Louis S. Roberts, III

/s/ J. Ryan Will_______________

J. RYAN WILL

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