Free Response to Discovery - District Court of Delaware - Delaware

Case 1:05-cv-00013-GMS

Document 103

Filed 04/17/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JIMMIE LEWIS, ) ) Plaintiff, ) ) v. ) ) ) WARDEN RAPHAEL WILLIAMS, et al., ) ) Defendants. )

CONSOLIDATED C.A. No. 05-013-GMS C.A. No. 05-051-GMS C.A. No. 05-052-GMS Jury Trial Requested

STATE DEFENDANT WARDEN RAPHAEL WILLIAMS' RESPONSES TO PLAINTIFF'S REQUEST FOR ADDRESSES [RE: D.I. 100 & 102] Pursuant to the Federal Rules of Civil Procedure and the Court's Order dated April 9, 2007 (D.I. 102), State Defendant Warden Raphael Williams ("Warden Williams") hereby responds to Plaintiff's request for addresses in his Motion for Discovery (D.I. 100) as follows: RESPONSE TO REQUEST FOR ADDRESSES Provide last known addresses for the following individuals: Dr. Joshi, Archie Armstrong, Mr. Fish, Mack Reynolds, Aaron Goines, C/O Cumberback, C/O Harriford, C/O Presley, Lt. Mitchell, Nanette Bordley, Tamiko Chaffer, C/O Hardgrave, Diane Hernandez, Ms. Newman, Dr. Boston, Dr. Ali, Georgia Sutton, and Nurse Inna. RESPONSE: State Defendant Warden Williams states as follows: 1. Upon information and belief, Dr. Joshi, Mr. Fish, Diane Hernandez, Dr. Boston, Dr. Ali, Georgia Sutton and Nurse Inna were not employees of Howard Young or DCC. Rather, the aforementioned individuals were employees of the contracted medical provider. The aforementioned individuals no longer work at Howard Young or DCC and neither Howard Young nor DCC maintained personnel files on these individuals. Therefore, there are no known addresses for these individuals. 2. Records indicate that there are no known individuals by the names of Aaron Goines or Mack Reynolds who worked for Howard Young or DCC.

Case 1:05-cv-00013-GMS

Document 103

Filed 04/17/2007

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3. Upon information and belief, the following individuals are currently employed by the Department of Correction: Lt. John Mitchell Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977 C/O Tamiko Schaffer Webb Correctional Facility 200 Greenbank Road Wilmington, DE 19808 4. Last known addresses of former employees of Howard Young: Archie Armstrong 228 Flower Street Chester, PA 19013 William Harriford 816 Townsend Boulevard Dover, DE 19901 Annette Newman 1605 Bonwood Rd. Alban Park Wilmington, DE 19805 Charles Pressley 1251 S. Peach Street Philadelphia, PA 19143 5. Upon information and belief, last known addresses of former employees of DCC: Nanette Bordley P.O. Box 1033 Dover, DE 19903 Amanda Cumberbatch 15 Hogan Circle Middletown, DE 19709

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Case 1:05-cv-00013-GMS

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Filed 04/17/2007

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Gwen Hargreaves RR2 Box 150-20 Frankford, DE 19945 DEPARTMENT OF JUSTICE STATE OF DELAWARE /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 Attorney for the State Defendants

Dated: April 17, 2007

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Case 1:05-cv-00013-GMS

Document 103

Filed 04/17/2007

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CERTIFICATE OF SERVICE
I, Erika Y. Tross, Esq., hereby certify that on April 17, 2007, I caused a true and correct copy of the attached State Defendant Warden Raphael Williams' Responses to Plaintiff's Request for Addresses [Re: D.I. 100 & 102] to be served on the following individual in the form and manner indicated: NAME AND ADDRESS OF RECIPIENT(S): Inmate Jimmie Lewis SBI # 506622 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977 MANNER OF DELIVERY: One true copy by facsimile transmission to each recipient Two true copies by first class mail, postage prepaid, to each recipient Two true copies by Federal Express Two true copies by hand delivery to each recipient

/s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General Delaware Department of Justice Carvel State Office Building 820 N. French Street, 6th Floor Wilmington, DE 19801 302-577-8400