Instructions: Initial Disclosures

This template was prepared by the Justice & Diversity Center, a nonprofit organization, and is not an official
court form. It can be used in certain civil lawsuits in the Northern District Court of California. This template
provides guidance only. Using this template does not guarantee any result in your case.

HOW TO GET LEGAL INFORMATION AND ADVICE

This packet provides general guidance about preparing Initial Disclosures. Before serving this
document, make an appointment for free legal information and advice at one of the Legal Help Centers.

If the case is assigned to a judge in the San Francisco, Oakland, or Eureka federal courthouse,
do one of the following:

Call the appointment scheduling line for the Federal Pro Bono Project: 415-782-8982

Sign up in the appointment book at either:

450 Golden Gate Ave., 15th Floor, Room 2796, San Francisco or
1301 Clay Street, 4th Floor, Room 470S, Oakland

Email us at [email protected]
This email is to schedule appointments only-no legal advice is given over email.

If the case is assigned to a judge in the San Jose federal courthouse, do one of the following:

Call the appointment scheduling line for the Federal Pro Se Program: 408-297-1480

Monday to Thursday 9:00 am - 12:00 pm, drop in at

The Law Foundation of Silicon Valley, 152 North 3rd St., 3rd Floor, San Jose
Monday to Thursday 1:00 pm - 4:00 pm, drop in at
280 South 1st Street, 2nd Floor, Room 2070, San Jose

WHEN TO PREPARE INITIAL DISCLOSURES

1. Figure out the due date. When the case was filed, the Clerk issued an Initial Scheduling Order,
which set the date for exchanging Initial Disclosures. They are normally due before the Case
Management Conference, but you should look at the Scheduling Order for the exact date.

2. Begin working at least a week before. While the template is not long, it may take time to gather the
information you need to complete it.
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 HOW TO COMPLETE THIS INITIAL DISCLOSURES TEMPLATE

 Understand “Initial Disclosures.” These lists tell the other parties what evidence will be used to
prove the claims and defenses in the case. It is important that your Disclosures are complete. You are
required to provide all the information that you currently know and that you can reasonably figure
out. It is a good idea to look back at your disclosures regularly to make sure you have not missed
anything. If you need to add or change information - a person, a document, or a description - you can
use this template again. Check the box for Supplemental or Amended on the first page.

 Fill in the case information. Fill in all the blanks on the first page.
 Complete Section 1 “List of Witnesses.” Before writing, count the number of people you might want
to testify or whose written statements you might want to use at trial. Make copies of the Section 1 page
so you have room for each person. List the name and, if you know it, the contact information of the
person. Briefly describe what the person knows about the case.

 Complete Section 2 “List of Documents and Things.” The term “Document” here is used broadly
and can include photos, audio recordings, emails, and other electronically-stored information. Before
writing, count the number of categories of documents you might want to use. Make copies of the
Section 2 page so that you have room for each. Describe categories of documents that you have that
you might use to support your claims or defenses. Then describe where those documents are located
such as “plaintiff” or “Dr. Jones, 1234 Street, City.”

 If you are the Plaintiff or Claimant, complete Section 3 “Damages Computation.” Write down
each category of damages you are seeking, and any dollar totals or estimates. For example, if you
were forced to miss work, list a category like “lost wages,” and write out your calculation (“40 hours
x $15 per hour = $600”). Keep any documents that you use to make your calculations because the
other side may ask you for them.

 If you are a Defendant, complete Section 4 “Liability Insurance.” Defendants must state whether
or not they have any insurance for the claims in the lawsuit.

 Number the pages. Count the number of pages in your final Disclosures. On each page, write in the
case number, page number and the total number of pages.

 Review and sign. Read the entire document to make sure everything is complete and correct.
 Prepare the Certificate of Service. Each document that you file must be “served” on each party,
usually by sending it in the mail. Follow the instructions on the Certificate of Service.

SERVING YOUR INITIAL DISCLOSURES

1. Make copies. Once the documents are complete, make one copy for each party in the case.
2. Serve the Disclosures. Be sure the Disclosures and Certificate are served on each party. Do not
send a copy to the Court.

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 TIMELINE: AFTER INITIAL DISCLOSURES

The timeline below lists what generally happens after Initial Disclosures are exchanged. The Legal Help
Centers (see page 1) can provide guidance about these steps and have many other templates for you to use.
Each party makes sure its Initial
Each party sends the Disclosures are correct and sends
others its Initial out any additions or changes
Disclosures (ongoing)

"Discovery": parties send and Parties follow deadlines set

respond to formal requests for by the Court in the Scheduling
documents and other Order
information and do depositions (ongoing)
(lasting several months)

STAY UP TO DATE

1. Update your contact information. File a notice with the Clerk right away if your address, email, or
phone number changes, or you may miss important deadlines, causing you to lose your case.
2. Check your mail. Be sure to check regularly for documents from the Court and opposing side.

3. A list of all of the documents that have been filed, and (usually) the documents themselves can
be viewed online. See Chapter 7 of the Handbook for Pro Se Litigants (see below), and contact
the Legal Help Center for information about how to access the documents (see page 1).

UNDERSTANDING THE LAWS AND RULES

The Legal Help Centers (see page 1) are the best resource for people without lawyers. There are other
resources for understanding the laws and rules of the Court:
1. Handbook for Pro Se Litigants. The Handbook is a procedural guide for people who are
representing themselves. It was prepared by the Court and is available at the Clerk’s Office or on the
Court’s website at www.cand.uscourts.gov/prosehandbk.

2. Legal Research Guide for Pro Se Litigants. The Guide provides information for people who are
representing themselves about how to do legal research, like finding statutes and decisions in other
cases. It was prepared by the Justice & Diversity Center and is available at the Legal Help Centers
and at http://www.cand.uscourts.gov/Legal-Help-Center-Templates.

3. Federal Rules of Civil Procedure. These Rules explain the procedures from filing through trial for
all civil cases in the federal courts across the country, and are available at
http://www.uscourts.gov/sites/default/files/rules-of-civil-procedure.pdf.

4. Local Rules. The Local Rules follow the same numbering as the Federal Rules of Civil Procedure,
but generally provide more detail. They apply in this District only, and are available at
http://www.cand.uscourts.gov/localrules/civil.

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 1 Your name: PEACE LOVE LIGHTNING
2 Address: c/o 1376 Haight St
3 San Francisco, CA 94117

4 Phone Number: 415 492-7730

5 E-mail Address: [email protected]
6 Pro se
7
8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA
10 Division [check one]: 
✔ San Francisco  Oakland  San Jose  Eureka
11
)
12 PEACE LOVE LIGHTNING ) Case Number: 23-cv-05067-TSH
)
13 [Name]
)
14 )
Plaintiff, ) ____________________________________’s
15 )
vs. ) INITIAL DISCLOSURES [check one]
16 CITY OF BARTLETT (TN); ) 
✔ Original
)
17 PATROL OFFICER # 1; )  Supplemental
)
18 PATROL OFFICER WORTHY; )  Amended
)
19 SWAT OFFICER GIANNINI )
)
20 )
)
21 Defendant. )
22
23
24
25
26
27 [See the Instructions for more information about preparing Initial Disclosures.]
28

INITIAL DISCLOSURES
CASE NO. 23-cv-05067-TSH 1
; PAGE ____ 5
OF ____ [JDC Rev.2017]
 1 1. List of Witnesses
Fill in the table below with the name, and if you know, the address and telephone number of each
2 person whose testimony or written statements you might use to support your claims or defenses.
Briefly write a description of what the person knows. Use additional pages as needed.
3
Name of Person Person’s Address and Description of what the person
4 Telephone Number knows

5 CITY OF BARTLETT ATTORNEY can answer why incident was

6 6400 Stage Rd allowed to continue even though

7 Bartlett, TN 38134 no crimes were alleged

8
9 City of Bartlett 3730 Appling Rd. can testify why Plaintiff taken from

10 Patrol Officer Bartlett, TN 38133 scene to 2nd location where he

11 Worthy 901 385-5555 was eventually pronounced dead

12 City of Bartlett 3730 Appling Rd can testify how long Plaintiff was
13 SWAT Officer Bartlett, TN left in the backseat of squad car
14 Giannini 901 385-5555 with no air on 100+ degree day

15
Bank of America P.O. Box 105576 testify that the Plaintiff's debit card
16
Fraud Department Atlanta, GA 30348 was used by someone other than
17
Representative 800 432-1000 plaintiff while plaintiff in custody
18
19
20 Emergency Room 2986 Kate Bond Rd testify to Plaintiff's state of mind &

21 Physician St.Francis Bartlett, TN 38133 statements made of terror when

22 Hospital, Bartlett 901 820-7000 Plaintiff regained consciousness

23
24
25
26
27
28

INITIAL DISCLOSURES
CASE NO. 23-cv-05067-TSH 2
; PAGE ____ 5 [JDC Rev.2017]
OF ____
 1 2. List of Documents and Things
Fill in the table below with a list of each category of documents, electronically-stored
2 information, or other item you may use to support your claims or defenses. For each category,
write in its location, such as “plaintiff” or “Dr. Jones, 1234 Street, City.” Use additional pages
3 as needed.
4 Category Location
of Document, Electronically Stored of Document, Electronically Stored
5 Information, Item, or Tangible Thing Information, Item, or Tangible Thing
6 Squad Car Camera Footage from Cruiser Bartlett Police Department
7 that Plaintiff was detained in on June 17,
8 2023.
9 Body Cam Footage of 3 Defendants Bartlett Police Department

10 for June 17, 2023

11
12 Radio/phone recordings of communica- Bartlett Police Department

13 tions between Officers and their

14 headquarters on June 17, 2023

15 Parking lot camera footage from Wal-Mart 8400 Stage Rd, Bartlett, 38133

16 scene at Wal-Mart on June 17, 2023

17
18 GPS data of the 3 Bartlett squad cars on Bartlett Police Department

19 day of June 17, 2023 showing that

20 Plaintiff was driven to another location

21 Weather Information for Bartlett, TN Online at Weather.com

22 on June 17, 2023
23
24 Emergency Room Camera footage from St. Francis- Bartlett

25 St, Francis Hospital on JUne 17, 2023 2986 Kate Bond Rd

26 Bartlett, TN 38133

27
28

INITIAL DISCLOSURES
CASE NO. 23-cv-05067-TSH 3
; PAGE ____ 5
OF ____ [JDC Rev.2017]
 1 3. Plaintiffs/Claimants: Damages Calculation
List each kind of harm you experienced. For each, calculate the amount owed and how you came
2 up with that number.
Defendants were given the Plaintiff's Contract-Offer with amounts clearly stated. By
3 ______________________________________________________________________________
continuing incident after reading the Contract Card they agreed to $1,650,000.00 in
4 ______________________________________________________________________________
fees. (10 separate fingerprint impressions @ $50,000.00 each; 2 separate likeness
5 ______________________________________________________________________________
impression photos @ $500,000.00 each; and 10 questions answered @ $15,000 each);
6 ______________________________________________________________________________
$2500.00 Bail posted and never returned; $229.00 charge on debit while in custody;
7 ______________________________________________________________________________
29 Hours Detained @ $10,000 per hour for $290,000.00; 3 civil rights violations @
8 ______________________________________________________________________________
$1,000,000.00 each for $3,000,000.00; $10,000,000.00 for wrongful death.
9 ______________________________________________________________________________
$350.00 filing fee; TOTAL OF $14,943,079.00
10 ______________________________________________________________________________
11 a) Defendants: Liability Insurance
If you have liability insurance for any of the claims in the lawsuit, write the name of the insurer
12 and type of policy below.
13 ______________________________________________________________________________
14 ______________________________________________________________________________
15 ______________________________________________________________________________
16 ______________________________________________________________________________
17 ______________________________________________________________________________
18
19 Date: 12/27/23 Signature:
20 Printed name: PEACE LOVE LIGHTNING
21 Pro Se
22
23
24
25
26
27
28

INITIAL DISCLOSURES
CASE NO. 23-cv-05067-TSH 4
; PAGE ____ 5
OF ____ [JDC Rev.2017]
 1 CERTIFICATE OF SERVICE OF DOCUMENT OTHER THAN COMPLAINT
* You must serve each document you file by sending or delivering to the opposing side. Complete
2 this form, and include it with the document that you file and serve.*
3 PEACE LOVE LIGHTNING
1. Case Name: _____________________________ CITY OF BARTLETT (TN), ET AL.
v. ________________________________
4 23-cv-05067-TSH
2. Case Number: _____________________________________________________________
5 3. What documents were served? Initial Disclosures
6 4. How was the document served? [check one]
7 Placed in U.S. Mail
8 Hand-delivered
9 Sent for delivery (e.g., FedEx, UPS)
10 Sent by fax (if the other party has agreed to accept service by fax)
11 5. Who did you send the document to? [Write the full name and contact information for
each person you sent the document. Do NOT send Initial Disclosures to the Court.]
12
ATTY Ed McKenney, Jr
_____________________________________ _____________________________________
13
CITY OF BARTLETT ATTORNEY
_____________________________________ _____________________________________
14
6400 Stage Rd
_____________________________________ _____________________________________
15
Bartlett, TN 38134
_____________________________________ _____________________________________
16
17 March 6, 2024
6. When were the documents sent? ______________________________________________
18 7. Who served the documents? [Whoever puts it into the mail, faxes, delivers or sends for
delivery should sign, and print their name and address. You can do this yourself.]
19
20 I declare under penalty of perjury under the laws of the United States that the foregoing
21 is true and correct.
22 Signature: _____________________________________________________
23 PEACE LOVE LIGHTNING
_____________________________________________________
Name:
24 Address: c/o 1376 Haight St
_____________________________________
25 San Francisco, CA 94117
_____________________________________
26
27
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CERTIFICATE OF SERVICE [JDC TEMPLATE Rev. 05/2017]