Case 1:06-cv-00778-GMS
JOSEPH R. BIDEN, III
Attorney General
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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
[New Castle County-Civil Division]
May 11, 2007
The Honorable Gregory M. Sleet United States District Court District of Delaware J. Caleb Boggs Federal Building 844 N. King Street Wilmington, DE 19801 Re: Dear Judge Sleet: Please allow this letter to reflect State Defendant Thomas Carroll's response in opposition to Plaintiff's Motion for Order to Compel Defendant Thomas L. Carrol [sic] to Place Jimmie Lewis into Protective Custody (the "Motion for Preliminary Injunction") (D.I. 10). On April 20, 2007, Inmate Jimmie Lewis, SBI #506622, asked the officers at the Delaware Correctional Center to place him in protective custody. (Exhibit A at ¶ 2). Mr. Lewis's request for protective custody was based on his belief that two inmates were threatening him while he was housed on the Special Needs Unit. (Exhibit A at ¶ 2; Exhibit B). Mr. Lewis was placed in protective custody the same day as his request and he remained there until May 4, 2007, when he was transferred to the Infirmary. (Exhibit A at ¶ 3; Exhibit C). Mr. Lewis is, at present, still housed in the Infirmary but he will be transferred back to protective custody after the medical staff in the Infirmary discharges him. (Exhibit A at ¶ 3). Lewis v. Carroll, et al., D. Del., C.A. No. 06-778-GMS
Case 1:06-cv-00778-GMS
The Honorable Gregory M. Sleet May 11, 2007 Page 2
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Mr. Lewis's classification in protective custody is reviewed on a weekly basis. (Exhibit A at ¶ 4). However, Mr. Lewis will remain in protective custody until he no longer believes it necessary and signs off on a statement to that effect. (Id.). Because Mr. Lewis is housed in protective custody and will remain there until he no longer believes the inmates are threatening his life, State Defendant Carroll asks that Lewis's Motion for Preliminary Injunction be denied as moot. If the Court has any questions or concerns, or believes that a more formal response from State Defendant Carroll is required, please contact the undersigned counsel at (302) 577-8400. Thank you. Sincerely, /s/ Erika Y. Tross Erika Y. Tross Deputy Attorney General Attorney for State Defendant Thomas Carroll cc: Jimmie Lewis, Plaintiff Enclosures
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