IN THE UNITED STATES DISTRICT COURT FOR 

THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

DAVID W. JAHN, ) 

 ) 

 Plaintiff, ) 

 ) 

vs. ) CASE NO.: 2:06-cv-623 

 ) 

REGINALD JAMES WASHINGTON, ) 

individually, and ) 

GROCERY SUPPLY COMPANY, ) 

 ) 

 Defendants. ) 

INITIAL DISCLOSURES OF PLAINTIFF DAVID W. JAHN

 Comes now the Plaintiff, David W. Jahn, and files this, his initial disclosures: 

A. INDIVIDUALS WITH DISCOVERABLE INFORMATION:

1. David W. Jahn is the Plaintiff to this accident, 449 Butler Road, Lot B-1, 

Dothan, Alabama, 36305. It is expected Mr. Jahn would testify regarding the accident 

which he was involved and would also testify as to his damages and medical treatment. 

2. Reginald James Washington is the Defendant, 1023 North 8th Avenue, 

Pensacola, Florida, 32501. It is expected Mr. Washington will testify regarding the accident 

occurring between him and Plaintiff David W. Jahn. 

3. Oscar De Leon, Jr., Route 10, Box 229.5, Harlingen, Texas, 78550. It is 

believed that Mr. De Leon was a witness to the accident. It is expected he will testify as to 

what he observed while at the accident scene. 

4. David Turman, Alabama State Trooper, Evergreen, Alabama, Office. Based 

on information and belief, Officer Turman investigated the accident made the basis of this 

lawsuit. 

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5. Ellis Farley, Alabama State Trooper, Evergreen, Alabama, Office. Based on 

information and belief, Officer Farley investigated the accident made the basis of this 

lawsuit. 

6. Appropriate corporate representatives of Grocery Supply Company. It is 

anticipated that representatives of Grocery Supply Company will testify in depositions 

concerning questions and/or discovery posed by Plaintiff in any 30(b) (6) deposition notices. 

7. Any and all medical physicians, medical providers and/or other medical 

personnel. It is anticipated that the testimony of Plaintiff’s treating physicians, medical 

providers, EMS personnel, etc. may be warranted under the facts of this case. It is expected 

that those medical providers will testify as to their personal observations, as well as the 

injuries and/or treatments of Plaintiff David W. Jahn. 

8. Discovery is currently underway. If additional witnesses are located who 

have information pertaining to this case, those witnesses will be disclosed to Defendant. 

B. RELEVANT DISCOVERABLE DOCUMENTS: 

 1. The Alabama Uniform Accident Report. 

 2. Any documents, notices, correspondence exchanged between or among the 

parties. 

 3. Photography of Plaintiff depicting his injuries. 

 4. Any photographs of the vehicles involved in the accident. 

 5. Medical records and bills from Georgiana Hospital, 515 North Miranda 

Avenue, Georgiana, Alabama, 36033. 

6. Medical records and bills from Southern Bone & Joint, 1500 Ross Clark 

Circle, Dothan, Alabama, 36301. 

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7. Medical records and bills from Southeast Alabama Medical Center, 1108 

Ross Clark Circle, Dothan, Alabama, 36301. 

8. Medical records and bills from Anesthesia Consultants, 1108 Ross Clark 

Circle, Ste.700, Dothan, Alabama, 36301. 

9. These documents are available for copying at mutually agreed time and 

place between parties. 

10. Discovery is ongoing in this case. If any additional discoverable nonprivileged information is obtained, that information will be produced to Defendant. 

C. DAMAGES CALCULATIONS: 

1. Plaintiff will be seeking damages for medical bills. 

 a. Medical bills already incurred. 

 b. Future medical bills to be determined later. 

 2. Pain and suffering, disfigurement and mental anguish. 

 3. Lost wages. 

D. INSURANCE COVERAGE: 

1. Coverage of any insurance agreements that may apply to pay a judgment or 

indemnify or reimburse payments made to satisfy a judgment. 

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 Dated this the 2nd day of October, 2006. 

 COCHRAN, CHERRY, GIVENS, 

 SMITH, LANE & TAYLOR, P.C. 

 s/ Terry G. Key 

 Terry G. Key ASB-2345-K36T 

 Attorney for Plaintiff 

 Post Office Box 927 

 Dothan, Alabama 36302 

 (334) 793-1555 

CERTIFICATE OF SERVICE

 I hereby certify that I have on this the 2nd day of October, 2006, electronically 

filed the foregoing pleading with the Clerk of the Court using the CM/ECF system which 

will send e-mail notification of such filing to the following attorneys of record: 

Shane M. Oncale, Esq. 

Eric D. Bonner, Esq. 

Clark, Oncale, Hair & Smith, P.C. 

800 Shades Creek Pkwy, Ste 850 

Birmingham, AL 35209 

 s/ Terry G. Key

 Of Counsel 

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