Free Interrogatories Propounded - District Court of Delaware - Delaware

_ Case 1:07-cv-00269-SLR Document 30 · Filed 05/08/2008 Page1 of4
T IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
KENNETH SMITH, g
Piainriff, g
v. g C.A. No. O7-269-SLR
STAN TAYLOR, THOMAS CARROLL, FIRST ) _
CORRECTIONAL MEDICAL, INC., and ) ‘**S¢ -·l=· ~¤v~
GAIL ELLER, ) ; H O ,._ ,
> AY —-as 2000
Defendants. ) · V 3 _
i ‘ 4..:;,. .,. _
PLAINTIFF'S FIRST SET OF INTERROGATOR ,_H“my§§§ ?%£g
T0 DEFENDANT STAN TAYLOR "’“ · W me
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Deman is hereby made for full and complete answers to the
following interrogatories under oath within thirty days. These
interrogatories are continuing and require that supplemental
responses be filed in accordance with Federal Rules of Civil
Procedure.
DEFINITION AND INSTRUCTIONS
A. The word "identify" and word derived therefrom shall have
the following meanings:
1. As applied to an individual, "identify" means to state:
a. The individuals name;
b. The individual's last known home aad business and
the telephone number for each such address;
c. The individual's occupation and title, if any, as
of the time to which the interrogatory is directed
and as of the present time; and
d. The role played by the individual in relation to
the subject matter of the interrogatory.

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v
2. As applied to a document, "identify" means to state:
a. Its nature (e.g., letter, memorandum, telegram,
note, drawing, photograph, etc.);
b. Its subject matter;
c. By whom it was made and to whom it was directed;
d. The date upon which it was made; and
e. The identify of all individuals or organizations who
` had possession of the orginal and any copies.
Note: Production of each doucument is acceptable in lieu of
stating the information in points (a) through (d) of this definnition.
3. "Describe" means to set forth fully the underlying facts
(rather then ultimate facts or conclusions of fact or law), including
date, time and lication.
4. "Person" shall mean any natural person, and corporation,
partnership, association, joint venture, from or other
business enterprise or legal entity, and means both sing-
ular and plural.
5. "DOC" shall mena the Department of Corrections this action
and any of its affiliates, subsidiaries, employees, independent
contractors, and any other person or entity under control of DOC.
6. "Your and your shall mean the Plaintiff in this action,
Kenneth Smith.
B. If you object to any of the interrogatories herein, whether
in whole or in part, on the ground that the information sought there-
in in privileged or confidential:
1. describe any such communication sought to be protected,
including its subject matter, and
2. Identify the individual by whom it was made, the in-
dividual to who it was directed, and all individuals present when

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f it was made; and
3. Identify any document in which it was recorded,
described ro summarized; and
4. Identify any such document sought to be protected.
J. _; gU INTERROGATORIES 1
l) Described prior to federal investigation, who evaluated
or monitored "Correctional Medical Services" performaces.
2) Explain the reponsibility too inmates under Title 11 Section
6536.
3) Detail sources available to inmates after filing medical
grievances, concerning medical issues dealing with Correctional
Medical Systems.
4) Outline evaluation process for Correctional Medical Services
in it°s providing medical services too inmates.
5) Who/how is it determined when inmate taken to outside
specialist, should inmate receive treatment prescribed by outside
specialist.
6) Name the agency(s) that evaluated Correctional Medical
Services, contract performance in providing medical services too
inmates.
7) Explain why since 1998 none of the recommendations of out-
side specialist followed. Even when reached your desk, via grievance
and personal letter process.
8) What did you base your decision, when denied plaintiff
receiving treatment ordered by specialist.
l_—El pages, if necessary

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9) State the procedure in effect in March, 1998 at
Delaware Correctional Center, for final resolution of inmate
grievances (medical). The aforemention means name of agencie(s)
or medical contractors.
10) State the name(s) of persons within "DOC" responsible for
monitoring contract between DOC and Correctional Medical Systems.
Delaware Correctional Center
1181 Paddock Road
Smyrna, DE 19977
DATED: May 6, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY copy of aforemention was furnished Xarhoulakos,
Deputy Attorney General, Department of Justice, Carvel State Office,
820 N. French St., Wilm, DE 19801.
By U.S. Mail this 6th day of May 2008 with sufficient postage
affixed thereto.
¤;% gz. ,/gg.
KENNETH SMITH, 193906