Free Interrogatories Propounded - District Court of Delaware - Delaware

Case 1:06-cv-00734-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

WILLIAM JOSEPH WEBB, JR., Plaintiff, v. MINNER, et. al., Defendants.

) ) ) ) ) ) ) ) )

C. A. No. 06-734-GMS JURY TRIAL REQUESTED

1st SET OF INTERROGATORIES DIRECTED TO PLAINTIFF Defendant Raphael Williams hereby requests Plaintiff fully answer, in writing and under oath, each of the following interrogatories within 30 days of receipt pursuant to Fed.R.Civ.P. 33. These interrogatories are continuing and the information requested must be kept current by supplementation. As used in these interrogatories, "you" or "yours" means and refers to the Plaintiff, his attorney(s) and their agents and employees.

Case 1:06-cv-00734-GMS

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INTERROGATORIES 1. Identify by name, address, and telephone number all persons with

knowledge of the facts as to each allegation as set out in your complaint(s) and identify those persons that have been interviewed on your behalf and as to the interview, state: the date, the location, the subject matter and any documents discussed, identified or provided by that person. Answer:

-2-

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2.

For each allegation you are presenting in this matter, state with

particularity and specificity (please provide the complete details including dates, times, and locations) the complete factual basis for each allegation and identify all persons having knowledge as well as each and all documents or other items of evidence in your possession that relate to each claim. Answer:

3

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3.

Identify with specificity the injuries that you have sustained as a result of

the claims made in this action. List in chronological order all health care providers (e.g. doctors, dentists, physicians, surgeons, therapists, etc.) that have diagnosed, treated and examined you for these injuries and identify the corresponding medical records that were generated as a result of your treatment. Answer:

4

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4. years.

Identify all of your medical conditions and treatments for the past ten (10)

List in chronological order all health care providers (e.g. doctors, dentists,

physicians, surgeons, psychiatrists, therapists, etc.) that have diagnosed, treated and examined you for these conditions and identify the corresponding medical records that were generated as a result of your treatments. Answer:

5

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5.

Identify by name, address, phone number, location, date and persons

present, all individuals, including inmates, with whom you spoke to in connection with this matter. State whether any documents or memoranda were prepared relating to these discussions. This includes, but is not limited to, all assistance provided by or to any inmate in this litigation and Seawright and Woods v. Taylor, C.A. No. 05-576. Answer:

6

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6.

State and describe with particularity all incidents of lead exposure that you

were subjected to and lead soldering that you witnessed while incarcerated by the Delaware Department of Correction. Include the time, date, and location of the incidents, the name(s), addresses and telephone numbers of the persons present or who have knowledge of the acts, and the grievances that you filed as a result of these incidents. Answer:

7

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7.

List in chronological order the names of all your employers (legal or

otherwise), location of the job, salary, position or duties of position and inclusive periods of such employment to the present time. Answer:

8

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8.

List in chronological order all of your formal education. Please include

the name and address of each educational institution or school, the dates of your attendance and the degree(s) awarded. Answer:

9

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STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Catherine Damavandi Catherine Damavandi (#3823) Deputy Attorney General 820 North French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 Attorney for Raphael Williams

DATED: May 14, 2008

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Case 1:06-cv-00734-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

WILLIAM JOSEPH WEBB, JR., Plaintiff, v. MINNER, et. al., Defendants.

) ) ) ) ) ) ) ) )

C. A. No. 06-734-GMS JURY TRIAL REQUESTED

CERTIFICATE OF SERVICE I hereby certify that on May 14, 2008 I electronically filed Defendant Raphael Williams' First Set of Interrogatories Directed to Plaintiff with the Clerk of Court using CM/ECF. I further certify that on May 14, 2008, I caused the within document to be mailed to the following non-registered participant by United States Postal Service: William J. Webb, Jr., SBI#256056 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977

/s/ Catherine Damavandi Deputy Attorney General, ID #3823 Department of Justice 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendant Raphael Williams

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