Sample Initial Disclosures Letter Under Rule 26(a)(1) for Plaintiff in United States District Court

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This sample initial disclosures letter under Rule 26(a)(1) for plaintiff is sent pursuant to Federal Rule of Civil Procedure 26(a)(1). The letter has been revised and updated in December 2016 and is used to disclose the individuals and entities likely to have discoverable information supporting the claims of plaintiff, individuals and entities associated with plaintiff, individuals and entities associated with defendants, third-party witnesses, categories and location of documents,  computation of damages and any relevant insurance information. The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.