Case 1:09-cv-06746 Document 34 Filed 12/23/09 Page 1 of 5

UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

DREW W. PETERSON, )
)
Plaintiff, ) Case No. 1:09-cv-06746
)
v. ) Hon. Ronald A. Guzman
) U.S. District Judge
JPMORGAN CHASE BANK, NA, )
d/b/a “CHASE”, ) Hon. Morton Denlow
) Magistrate Judge
Defendant. )
PLAINTIFFS' INITIAL DISCLOSURES
PURSUANT TO FED. R. CIV. P. 26(A)(1)
NOW COMES the Plaintiff, DREW W. PETERSON, ("Plaintiff"), by his attorney,
Walter Maksym, and makes the following Initial Disclosures Pursuant to Fed. R. Civ. P.
26(A)(1):
A. The name and, if known, the address and telephone number of each individual
likely to have discoverable information that the disclosing party may use to support Plaintiffs'
claims, unless solely for impeachment, identifying the subjects of the information:
Response:
Drew W. Peterson
6 Pheasant Chase Court
Bolingbrook IL 60490

(Mr. Peterson has knowledge of facts alleged in Plaintiff’s Complaint. He is currently

being held, pending trial, at the Will County Adult Detention Center, 95 South Chicago
Street, Joliet, IL (Tel. 815) 740-1250. Contact Plaintiff's Attorney – All
communications must be arranged through ihm and the Will Counrty Sheriff’s Office.)

Joel A. Brodsky
8 S. Michigan Avenue, 32nd Floor
Chicago, IL 60603
(Tel. 312-701-3000)
(Mr. Brodsky has knowledge of facts alleged in Plaintiff’s Complaint.)

Stephen Peterson (Plaintiff’s Son)

6 Pheasant Chase Court
Bolingbrook IL 60490
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(Plaintiff’s son may have knowledge of facts alleged in Plaintiff’s Complaint.)

Richard J. Reimer, Esq.

(Attorney for the Board of Trustees of the Bolingbrook Police Pension Fund)
15 Spinning Wheel Road
Hinsdale, IL 60521
Tel: 630-654-9547
(Mr. Reimer may have knowledge of facts alleged in Plaintiff’s Complaint relating to the
proceeding before and actions of said Board relating to Plaintiff.)

Michael Dunn, Branch Manager of CHASE’S Naperville Hobson Branch (Mr. Dunn may
have knowledge of facts alleged in Plaintiff’s Complaint.)

Charles Scharf (CEO CHASE Consumer Lending – Arizona Office)

(Mr. Scharf may have knowledge of facts alleged in Plaintiff’s Complaint.)

Orest Lechnowsky (CHASE Assistant General Counsel – Arizona Office)

(Mr. Lechnowsky may have knowledge of facts alleged in Plaintiff’s Complaint.)

Denise Desrosiers (CHASE Attorney – Arizona Office)

(Ms. Desrosiers may have knowledge of facts alleged in Plaintiff’s Complaint.)

Presently unknown fact witnesses whose identities may become known during discovery
or that have been or may hereafter be disclosed by Defendant.

(B) Copies of, or a description by category and location of, all documents, data
compilations, and tangible things that are in the possession, custody, or control of the party and
that the disclosing party may use to support its claims or defenses, unless solely for
impeachment:
Response:
Documents (copies previously served and/or mailed enclosed herewith):

Mortgage on the subject property that was duly recorded with the Will County Recorder
of Deeds on June 6, 2005 as Document Number R2005094431 (the “HELOC”
(Exhibit “A” to Plaintiff’s Complaint)

Indictment and Arrest Warrant dated May 7, 2009 (Exhibit “B” to Plaintiff’s Complaint)

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Suspension Letter” dated May 15, 2009 sent by CHASE to PETERSON (Exhibit “C” to
Complaint)

Affidavit of Orest Lechnowsky, CHASE’S Vice-President and Assistant General Counsel

(Exhibit “D” to Complaint).

Affidavit Christine Greigo, CHASE’S Investigative Specialist (Exhibit “E” to Plaintiff’s

Complaint)

Affidavit of Michael Dunn, CHASE’S Vice-President and Branch Manager of the its
Naperville Hobson Branch (Exhibit “F” to Plaintiff’s Complaint).

Affidavit of Keith McLendon, CHASE’S Vice-President and Assistant General Counsel

(Exhibit “G” to Plaintiff’s Complaint).

Plaintiff’s W-2 Statements for the years 2004, 2005, and 2006 previously propounded
to Defendant for admission as to their authenticity and previously served with Plaintiff’s
Memoranda in Support of Plaintiff’s' Motion to Expedite and Advance on Docket.

Decision and Order of the Board of Trustees of the Bolingbrook Police Pension Fund
declaring Plaintiff’s entitlement to and certifying payment to him.

Certificate of Payment of the Board of Trustees of the Bolingbrook Police Pension Fund
directing Plaintiff’s Pension to commence on November 10, 2007.
See copies documents previously produced mentioned above and served by mail.
Additionally:
Plaintiff's social security payment records that will have to be obtained from he Keeper
of Records or Secretary of the Social Security Administration, Washington, DC
(Plaintiff, or his son Stephen, who has his power of attorney, will sign any release
necessary to obtain copies of such records.)

Other W-2 Forms as may be obtainable from his employer, the Village of Bolingbrook
Police Department, for time periods relevant to his claims.

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(C) a computation of any category of damages claimed by the disclosing party, making
available for inspection and copying as under Rule 34 the documents or other evidentiary
material, not privileged or protected from disclosure, on which such computation is based,
including materials bearing on the nature and extent of injuries suffered;
Response:
Damages stated in Plaintiff's Complaint sought for Defendants acts and omissions
therein described. Plaintiff claims no physical injuries but claims emotional damages, , costs and
attorneys fees recoverable as stated in Plaintiff’s Complaint and to be shown at hearing or trial.
(D) Response:

None

2. Response:
No expert witnesses at this time. Disclosure is not yet due. Plaintiff reserves the right to
retain and disclose such expert and consulting witnesses as he may deem fit pursuant to the
applicable Federal Rule 26 and orders of court.
Investigation, discovery and preparation for trial continues.

Drew W. Peterson, Plaintiff,

By_s// Walter Maksym________________

Walter Maksym, his attorney

Walter Maksym
Attorney for Plaintiff
2056 N. Lincoln Avenue
Chicago, IL 60614-4525
Tel: 312.218.4475
e-mail: wmaksym@gmail.com

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