Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
KELVIN J. COCHRAN,
Plaintiff,
v.
CITY OF ATLANTA, GEORGIA;
and MAYOR KASIM REED, in his
individual capacity.
Defendants.

CASE NO.
1:15-cv-00477-LMM

CITY DEFENDANTS INITIAL DISCLOSURES

Defendants City of Atlanta and Mayor Kasim Reed (City Defendants) hereby
make their initial disclosures as follows:

(1) If any of the defendants are improperly identified, state defendants correct
identification and state whether such defendant(s) will accept service of
an amended summons and complaint reflecting the information furnished
in this disclosure response.
RESPONSE: N/A
(2) Provide the names of any parties whom defendants contend are necessary
parties to this action, but who have not been named by plaintiff. If
defendants contend that there is a question of misjoinder of parties,
provide the reasons for defendants contention.
RESPONSE: City Defendant does not contend that there is a question of
misjoinder of parties.

Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 2 of 7

(3) Provide a detailed factual basis for the defense or defenses and any
counterclaims or cross-claims asserted by defendants in the responsive
pleading.
RESPONSE: Defendants main defenses are as asserted:
1. Plaintiffs allegations fail to state claims for Counts One through Nine of his
Complaint; Plaintiff does not have standing to assert Count Two of his
Complaint.
2. Defendant Reed, sued in his individual capacity, is entitled to qualified
immunity on Plaintiffs federal claims.
These issues are fully briefed in City Defendants Motion to Dismiss and Reply
in Support of Motion to Dismiss. City Defendants reserve the right to supplement
this response.
(4) Describe in detail all statutes, codes, regulations, legal principles, standards
and customs or usages, and illustrative case law which Defendants contend are
applicable to this action.
RESPONSE:
Plaintiff brings his claims under the First and Fourteenth Amendments of the
United States Constitution pursuant to 42 U.S.C. 1983. Thus, all federal
regulations and the case law interpreting these amendments and statute (as
decided by the United States Supreme Court, the Eleventh Circuit, the district
courts therein, and other persuasive precedent) are applicable. Defendants further
direct the Plaintiff to all authorities cited in their Motion to Dismiss and Reply in
Support of Motion to Dismiss. City Defendants reserve the right to supplement
this response.

(5) Provide the name and, if known, the address and telephone number of
each individual likely to have discoverable information relevant to
disputed facts alleged with particularity in the pleadings, identifying the
subject of the information. (Attach witness list to Initial Disclosures as
Attachment A).
RESPONSE: See Attachment A.
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Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 3 of 7

(6) Provide the names of any person who may be used at trial to
presentevidence under Rules 702, 703, or 705 of the Federal Rules of
Evidence. For all experts described in F.R.Civ.P. 26(a)(2)(B), provide a
separate written report satisfying the provisions of that rule. (Attach
expert witness list and written reports as Attachment B).
RESPONSE: City Defendants have not retained any experts as of the making
of these disclosures. City Defendants will supplement this response at such time
as any expert is retained.
(7) Provide a copy of, or description by category and location of, all
documents, data, compilations, and tangible things in your possession,
custody, or control that are relevant to the disputed facts alleged with
particularity in the pleadings. (Attach document list and descriptions to
Initial Disclosures as Attachment C).
RESPONSE: See Attachment C.
(8) In the space provided below, provide a computation of any category of
damages claimed by you. In addition, include a copy of or description by
category and location of, 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, making such documents or evidentiary material available for
inspection and copying under F.R.Civ.P 34. (Attach any copies and
descriptions to Initial Disclosures as Attachment D).
RESPONSE: City Defendant has no damages except costs and fees for
defending this action.
(9) If defendants contend that some other person or legal entity is, in whole
or in part, liable to the plaintiff or defendants in this matter, state the full
name, address and telephone number of such person or entity and
describe in detail the basis of such liability.
REPONSE: City Defendant is not claiming at this time that some other person
or entity is liable to Plaintiff.
(10) Attach for inspection and copying as under F.R.Civ.P. 34 any insurance
agreement under which any person carrying on an insurance business
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Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 4 of 7

may liable to satisfy part or all of a judgment which may be entered in this
action or to indemnify or reimburse from payments to satisfy the
judgment. (Attach copy of insurance agreement to Initial Disclosures as
Attachment E).
RESPONSE: City Defendants do not have such insurance coverage.

Submitted this 21st day of May, 2015.

/s/ Y. Soo Jo
ROBERT N. GODFREY
Chief Counsel
GA Bar No. 298550
Y. SOO JO
Sr. Assistant City Attorney
GA Bar No. 385817
Attorneys for City Defendants
CITY OF ATLANTA LAW DEPARTMENT
55 Trinity Avenue, S.W.
Suite 5000 City Hall
Atlanta, Georgia 30303
(404) 546-4100 (main telephone)
(404) 546-4151 (direct telephone)
(404) 739-4888 (facsimile)
ysjo@atlantaga.gov

Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 5 of 7

ATTACHMENT A

1. Individuals named in Plaintiffs Complaint and Initial Disclosures, with the

exception of attorneys in the office of the City of Atlanta Law Department,
whose information, if any, would be protected under attorney client privilege
and the work product doctrine.

City Defendants reserve the right to supplement this list.

City employees may be contacted through undersigned counsel

Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 6 of 7

ATTACHMENT C

The following documents, or copies thereof, are in the possession of

Defendant City of Atlanta.
City of Atlanta Code of Ordinances
City of Atlanta Departments HR standard operating procedures, employee
handbooks, policies, rules, manuals and guidelines governing conduct of City
employees
Plaintiffs personnel files
Plaintiffs EEOC complaints
Internal investigation
City Defendants reserve the right to supplement this list.

Case 1:15-cv-00477-LMM Document 25 Filed 05/21/15 Page 7 of 7

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
KELVIN J. COCHRAN,

Plaintiff,
v.
CITY OF ATLANTA, GEORGIA;
and MAYOR KASIM REED, in his
individual capacity.
Defendants.

CASE NO.
1:15-cv-00477-LMM

CERTIFICATE OF SERVICE
I hereby certify that on May 21, 2015, I electronically filed a copy of
DEFENDANTS INITIAL DISCLOSURES with the Clerk of Court using the CM/ECF
system which will send notice to all counsel of record.

/s/ Y. Soo Jo
Y. SOO JO
Sr. Assistant City Attorney
GA Bar No. 385817
Attorneys for City Defendants
CITY OF ATLANTA LAW DEPARTMENT
55 Trinity Avenue, S.W.
Suite 5000 City Hall
Atlanta, Georgia 30303
(404) 546-4100 (main telephone)
(404) 546-4151 (direct telephone)
(404) 739-4888 (facsimile)
ysjo@atlantaga.gov
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