Case 1:06-cv-00791-SLR
JOSEPH R. BIDEN, III
Attorney General
Document 31
Filed 10/01/2007
Page 1 of 2
DEPARTMENT OF JUSTICE
NEW CASTLE COUNTY Carvel State Building 820 N. French Street Wilmington, DE 19801 Criminal Division (302) 5778500 Fax: (302) 577-2496 Civil Division (302) 577-8400 Fax: (302) 577-6630 TTY: (302) 577-5783 PLEASE REPLY TO:
KENT COUNTY 102 West Water Street Dover, DE 19904 Criminal Division (302) 739-4211 Fax: (302) 739-6727 Civil Division (302) 739-7641 Fax: (302) 739-7652 TTY: (302) 739-1545
SUSSEX COUNTY 114 E. Market Street Georgetown, DE 19947 (302) 856-5353 Fax: (302) 856-5369 TTY: (302) 856-2500
October 1, 2007
[New Castle County-Civil Division]
The Honorable Sue L. Robinson United States District Court District of Delaware J. Caleb Boggs Federal Building 844 N. King Street Wilmington, DE 19801 Re: Dear Judge Robinson: On September 19, 2007, Plaintiff Raymond L. Bruton, Sr., filed a Motion for Extension of Time to respond to discovery in the above-captioned matter (D.I. 29). State Defendants have no objection to Mr. Bruton's request for an extension of time to respond to State Defendants' discovery requests (D.I. 27). However, given that discovery closes in this matter on November 23, 2007, we ask that Mr. Bruton be given until no later than October 31, 2007 to respond to discovery. Mr. Bruton contends in his Motion that he needs to visit the Widener Law Library in order to respond to the State Defendants' discovery requests. Mr. Bruton is currently incarcerated at the Plummer Community Correctional Center where he is participating in the Crest drug treatment program. As a participant in Crest, Mr. Bruton is not permitted off grounds for the first few months of the program. Although Mr. Bruton is not permitted off grounds, he may submit any requests for legal research or materials to his counselor or another staff person at Plummer and the request will be forwarded to the law library staff of one of the other institutions who will respond to Mr. Bruton's request. This procedure has been used by other inmates in the past. Bruton v. Minor, et al., D. Del., C.A. No. 06-791-SLR
Case 1:06-cv-00791-SLR
The Honorable Sue L. Robinson October 1, 2007 Page 2
Document 31
Filed 10/01/2007
Page 2 of 2
Moreover, if need be, we can try to arrange for Mr. Bruton to visit the law library at the New Castle County Courthouse or one of the law libraries at the other correctional institutions. We ask, however, that the Court considers this alternative as a last resort given that Mr. Bruton is participating in the Crest drug treatment program. If the Court has any questions or concerns, or requires a more formal response from the State Defendants, please contact the undersigned counsel at (302) 5778400. Thank you. Sincerely, /s/ Erika Y. Tross Erika Y. Tross Deputy Attorney General Attorney for State Defendants cc: Raymond L. Bruton, Sr., Plaintiff