Free Response to Motion - District Court of Delaware - Delaware

as/14x2aa§6=1e;l2i>6-cvaQM13i4e$l¤,Fi Document 44-y3.|U Mgueqqqyag/,2006 Page 1 of 1 PAGE @2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LEONARD K. BAYLIS, )
Plaintifil i
v. i C. A. No. 06-11-SLR
STANLEY TAYLOR, et al., g
Defendants. g
AFFIDAQTT OF TODD Ijgéhjgk
I, Todd Kramer, having been duly sworn according to law, depose and state as folli iwsz
1. I make this Affidavit based upon personal information.
2. I am employed by the State of Delaware’s Department of Correction as a Senior Correctional
Counselor at the Delaware Correctional Center ("DCC") in Smyrna, Delaware.
3. On November 17, 2005, Plaintiff Leonard Baylis ("Plaintift") was transti rred from the Howard
R. Young Correctional Institution to DCC to attend the Greentree Substance Abuse Program.
4. On April 3, 2006, Plaintiff was transferred from the Grecntree Substance Abuse Program to the
Medium High Security aren of DCC due to his refusal to participate in the program.
5. On June 6, 2006, Plaintiff was transferred to Protective Custody, at his rr quest.
6. PlaintiH` requested that he be transferred from Protective Custody to DC(2’s Mental Health Unit.
Upon review and approval of the Mu1ti—Discip1ina.ry Team, Plaintiff was transferred to the Mental Health Unit
on June 12, 2006. 1
SWORN AND SUBSCRIBED before me this E day of June, 2006. , _
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