Free Response to Discovery - District Court of Delaware - Delaware

Case 1:06-cv-00263-GMS-MPT

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Filed 12/20/2007

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IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF DELA WARE JACK E. SMINKEY, Pro se Plaintiff, v. STATE OF DELA WARE, et aI., Defendants. : : : : : : : : :

C.A. No. 06-263***

DEFENDANTS' RESPONSES TO PLAINTIFF' THIRD REQUEST S FOR PRODUCTION OF DOCUMENTS 1.) Provide a listing of the last known home addresses of the below listed present or former employees of the Delaware State Police. A. Robert F. Tate B. David L. Baylor C. Valerie M. Robinson D. Ralph H. Davis III E. Herbert Douglas F. Christopher D. Foraker G. G. John A. Dillman III H. William Bullen I. Jeffrey Giles J. Rebecca B. McKnatt K. Willie E. Smith L. Gregory A. Warren M. Barbara L. Conley N. Diane E. Moss O. Bradford Powns Response: Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence.

2) Provide a listing of the last known home addresses of the below listed present or former employees of the Department of Correction. A. Thomas G. Baylor

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B. Dominque Brown C. Douglas A. Bounds D. Cassandra Arnold E. Karen Brandewie F. Dion Hawkins G. Karen Hawkins H. Donei Winder I. Christina Bates J. Susie A. Wilson K. Corrine Padilla L. Wilbur F. Justice Response: Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence.

3) Provide a listing of the last known home addresses of the ten employees terminated by DELDOT in August 2005. Response: Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence. 4). Provide a listing of the last known home addresses of the below listed present and former employees of the Delaware Psychiatric Center. A. B. C. D. E. F. Karen Stoppel Deborah Hammond Gloria Harrison Dr. David T. Springer Rita Marocco David Saxton Response: Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence.

5). Provide a copy of the "Task Force Report of the Delaware Psychiatric Center",

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Response:

Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence.

6). Provide a copy of the law regarding training of Department of Correction Personnel. Response: Objection, this request seeks information that is beyond the scope of Rule

26 and is not reasonably calculated to lead to admissible evidence. Without waiving this objection, please refer to 11 Del.C. § 6517 (8) and 29 Del.C. § 8926.

STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Marc P. Niedzielski Marc P. Niedzielski, I.D. #2616 Deputy Attorney General Carvel State Building 820 N. French St., 6th Flr. Wilmington, DE 19801 (302) 577-8400 Attorney for Defendants

DATE: December 20, 2007

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CERTIFICATE OF SERVICE I certify that on the date indicated below I served by e-mail a copy of the attached document on the following: Jack Sminkey 3402 Edgemont Avenue, # 333 Brookhaven, PA 19005 [email protected] /s/ Marc P. Niedzielski Marc P. Niedzielski (2616) Deputy Attorney General Department of Justice 820 North French Street Carvel Building, 6th Floor Wilmington, DE 19801 (302) 577-8324

DATED: December 20, 2007

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