Pamela Owen. Civil Rights. Defendant Bishop, Marshall & Weibel, P.s.'s Initial Disclosures. Final.9!28!2015

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UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF WASHINGTON AT TACOMA
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PAMELA S. OWEN,
Plaintiff,
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v.
FEDERAL HOUSING FINANCE AGENCY;
FEDERAL HOME LOAN MORTGAGE
CORPORATION; MTC FINANCIAL, INC.,
D/B/A TRUSTEE CORPS; BISHOP
MARSHALL & WEIBEL, P.S.; CHUCK E.
ATKINS, in his official capacity as Clark
County Sheriff,
No. 3:15-cv-05375-BHS
DEFENDANT BISHOP,
MARSHALL & WEIBEL,
P.S.s INITIAL DISCLOSURES
Defendants.
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Defendant Bishop, Marshall & Weibel, P.S. (Bishop), makes the following Initial
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Disclosures of discoverable information and documents pursuant to Fed. R. Civ. P.
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26(a)(1)(A) based on information currently and reasonably available to them.
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I.
WITNESSES (Fed. R. Civ. P. 26(a)(1)(A)(i))
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The following individuals are likely to have discoverable information that
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Defendant may use to support its claims or defenses, unless the use would be solely for
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impeachment:
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DEFENDANT BISHOP, MARSHALL &

WEIBEL, P.S.S INITIAL DISCLOSURES
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MARSHALL & WEIBEL, P.S.

720 OLIVE WAY, SUITE 1201
SEATTLE, WASHINGTON 98101-1801
206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
1. Name:
Address:
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Telephone Number:
Subjects of
Information:
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2. Name:
Address:
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Telephone Number:
Subjects of
Information:
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Bishop Designated Speaking Agent(s)

c/o Barbara L. Bollero, Esq.
720 Olive Way, Suite 1201
Seattle, WA 98101-1801
(206) 622-5306, ext. 5918
To the extent of its knowledge, unprivileged documents,
information, filings, court appearances, and communications
concerning Bishops representation of Freddie Mac in unlawful
detainer proceedings against Plaintiff.
Freddie Mac Designated Speaking Agent(s)

c/o Jody M. McCormick, Esq.
WITHERSPOON KELLEY
422 W. Riverside Ave., Ste. 1100
Spokane, WA 99201-0300
(509) 624-5265
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3. Name:
Address:
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Telephone Number:
Subjects of
Information:
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Federal Housing Finance Agency Designated Speaking Agent(s)

c/o Jody M. McCormick, Esq.
WITHERSPOON KELLEY
(509) 624-5265
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4. Name:
Address:
Telephone Number:
Subjects of
Information:
Bank of America, N.A. Designated Speaking Agent(s)

Unknown
Unknown

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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS

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5. Name:
Address:
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Telephone Number:
Subjects of
Information:
MTC Financial, Inc. Designated Speaking Agent(s)

Michael S. DeLeo, Esq.
PETERSON RUSSELL KELLY PLLC
1850 Skyline Tower
10900 NE Fourth Street
Bellevue, WA 98004-8341
(425) 462-4700
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6. Name:
Address:
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Telephone Number:
Subjects of
Information:
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Chuck E. Atkins
William P. Richardson, WSBA #42104
Clark County Prosecution Civil Div. P.O. Box 5000
1300 Franklin St.
Vancouver, WA 98660-2865
(360) 397-2478
To the extent of his knowledge, unprivileged documents,
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7. Name:
Address:
Telephone Number:
Subjects of
Information:
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Pamela S. Owen
3912 NE 57th Avenue
Vancouver, WA 98661
(360) 991-4758
To the extent of her knowledge, documents, information, filings,
court appearances, and communications concerning Bishops
representation of Freddie Mac in unlawful detainer proceedings
against her, her claims and defenses thereto, and damages.
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8. Name:
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All witnesses identified in all other parties Initial Disclosures,

Supplemental Disclosures, and Pretrial Disclosures, which are

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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
Address:
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Telephone Number:
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Subjects of
Information:
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II.
incorporated herein by this reference

As stated in that witnesses identification in any other partys
Initial Disclosures, Supplemental Disclosures, and Pretrial
Disclosures, which are incorporated herein by this reference
DOCUMENTS (Fed. R. Civ. P. 26(a)(1)(A)(ii))
The following categories of documents, electronically stored information, and
tangible things are in Defendants possession, custody, or control and may be used to
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support their claims or defenses, unless the use would be solely for impeachment:
NUMBER DESCRIPTION/CATEGORY
LOCATION
1.
To the extent maintained by Bishop,
c/o Barbara L. Bollero, Esq.
unprivileged documents, information, MARSHALL & WEIBEL, P.S.
filings, and communications
concerning Bishops representation of Seattle, WA 98101-1801
Freddie Mac in unlawful detainer
proceedings against Plaintiff.
2.
All documents referenced in all other
As stated in all other parties
parties Initial Disclosures,
Initial Disclosures, Supplemental
Supplemental Disclosures, and Pretrial Disclosures, and Pretrial
Disclosures, which are incorporated
Disclosures, which are
herein by this reference
incorporated herein by this
reference
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III.
COMPUTATION OF DAMAGES (Fed. R. Civ. P. 26(a)(1)(A)(iii))
Defendant is not claiming damages at this time, but reserves the right to seek costs of
suit and attorneys fees as may allowed by Plaintiffs Note, Deed of Trust, and by 15
U.S.C.1692k(a)(3), if warranted.
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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
IV.
INSURANCE AGREEMENTS (Fed. R. Civ. P. 26(a)(1)(A)(iv))
Defendant has a policy of lawyers professional liability insurance with Interstate Fire
and Casualty Company under which an insurance business may be liable to satisfy all or part
of a possible judgment in this action, or to indemnify or reimburse it for payments made to
satisfy any such judgment.
V. EXPERT TESTIMONY (Fed. R. Civ. P. 26(a)(2)(A))
Defendant has not yet identified any witnesses it may use at trial to present expert
opinion evidence under Fed. R. Ev. 702 705. Should Defendant choose to introduce such
expert opinion evidence at trial, full disclosure will be provided pursuant to Fed. R. Civ. P.
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26(a)(2).
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VI.
1.
RESERVATIONS
Defendant makes these Initial Disclosures based on the information
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reasonably and currently available to it. Defendant reserves the right to supplement these
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Initial Disclosures at any time in accordance with Fed. R. Civ. P. 26(e).
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2.
Defendant specifically reserves, and does not waive, any right to provide or
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use additional information, documents, witnesses, or expert testimony that may become
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available or be discovered during pendency of this litigation.
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3.
Defendant specifically reserves, and does not waive, any and all evidentiary
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objections and claims of privilege. Defendants Initial Disclosures and any Supplemental
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Disclosures are made subject to any and all such evidentiary objections and privilege claims.
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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
DATED this 29th day of September, 2015.
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/s/ Barbara L. Bollero
Barbara L. Bollero, WSBA #28906
Seattle, WA 98101-1801
Telephone: 206-622-5306
Facsimile: 206-622-0354
dweibel@bwmlegal.com
bbollero@bwmlegal.com
Attorneys for Defendant Bishop, Marshall
& Weibel, P.S.
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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
CERTIFICATE OF SERVICE
I hereby certify under penalty of perjury under the laws of the State of Washington
and the United States of America that on the 29th day of September, 2015, I served in the
manner indicated below the foregoing INITIAL DISCLOSURES OF DEFENDANT
BISHOP, MARSHALL & WEIBEL, P.S., to the following parties:
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Pamela S. Owen
3912 NE 57th Avenue
Vancouver, WA 98661
Plaintiff Pro Se
[X] By United States Mail

[ ] By Legal Messenger
[ ] By Federal Express
[ ] By CM/ECF
[X] By Email to:
pamela.owen99@gmail.com
Michael S. DeLeo, WSBA #22037

PETERSON RUSSELL KELLY PLLC
1850 Skyline Tower
10900 NE Fourth Street
Bellevue, WA 98004-8341
Attorneys for Defendant MTC
Financial Inc. d/b/a Trustee Corps
[ ] By United States Mail

[ ] By CM/ECF
[X] By Email to: mdeleo@prklaw.com
William P. Richardson, WSBA #42104

Clark County Prosecution Civil Div. P.O.
Box 5000
1300 Franklin St.
Vancouver, WA 98660-2865
Attorneys for Defendant Chuck E. Atkins

[ ] By CM/ECF
[X] By Email to:
Bill.Richardson@clark.wa.gov
Jody M. McCormick, WSBA #26351

WITHERSPOON KELLEY
Attorneys for Defendant Freddie Mac

[ ] By CM/ECF
[X] By Email to:
JMM@witherspoonkelley.com
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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS
Dated this 29th day of September, 2015, at Seattle, Washington.
/s/ Tamorah L. Burt

Tamorah L. Burt, Legal Assistant
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206/622-5306 FAX: 206/622-0354
No. 3:15-cv-05375-BHS

Pamela Owen. Civil Rights. Defendant Bishop, Marshall & Weibel, P.s.'s Initial Disclosures. Final.9!28!2015

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Pamela Owen. Civil Rights. Defendant Bishop, Marshall & Weibel, P.s.'s Initial Disclosures. Final.9!28!2015

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1

UNITED STATES DISTRICT COURT FOR THE

Disclosures of discoverable information and documents pursuant to Fed. R. Civ. P.

26(a)(1)(A) based on information currently and reasonably available to them.

WITNESSES (Fed. R. Civ. P. 26(a)(1)(A)(i))

The following individuals are likely to have discoverable information that

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

Bishop Designated Speaking Agent(s)

Freddie Mac Designated Speaking Agent(s)

Federal Housing Finance Agency Designated Speaking Agent(s)

Bank of America, N.A. Designated Speaking Agent(s)

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

concerning Bishops representation of Freddie Mac in unlawful

MTC Financial, Inc. Designated Speaking Agent(s)

All witnesses identified in all other parties Initial Disclosures,

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

incorporated herein by this reference

The following categories of documents, electronically stored information, and

COMPUTATION OF DAMAGES (Fed. R. Civ. P. 26(a)(1)(A)(iii))

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

INSURANCE AGREEMENTS (Fed. R. Civ. P. 26(a)(1)(A)(iv))

of a possible judgment in this action, or to indemnify or reimburse it for payments made to

satisfy any such judgment.

V. EXPERT TESTIMONY (Fed. R. Civ. P. 26(a)(2)(A))

Defendant makes these Initial Disclosures based on the information

Initial Disclosures at any time in accordance with Fed. R. Civ. P. 26(e).

available or be discovered during pendency of this litigation.

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

DATED this 29th day of September, 2015.

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

manner indicated below the foregoing INITIAL DISCLOSURES OF DEFENDANT

BISHOP, MARSHALL & WEIBEL, P.S., to the following parties:

[X] By United States Mail

Michael S. DeLeo, WSBA #22037

[ ] By United States Mail

William P. Richardson, WSBA #42104

[ ] By United States Mail

Jody M. McCormick, WSBA #26351

[ ] By United States Mail

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

Dated this 29th day of September, 2015, at Seattle, Washington.

MARSHALL & WEIBEL, P.S.

/s/ Tamorah L. Burt

DEFENDANT BISHOP, MARSHALL &

MARSHALL & WEIBEL, P.S.

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