Case 1:04-cv-01422-GMS
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Filed 06/07/2006
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
: : : Plaintiff, : : v. : : CATHY L. GUESSFORD, REBECCA : MCBRIDE, ROBERT F. SNYDER, THOMAS : : L. CARROLL, and STANLEY W. TAYLOR, JR. Defendants
JEROME K. HAMILTON, a/k/a ELOHIM CHEIKH AHMED,
C.A. No. 04-1422 (GMS) JURY TRIAL DEMANDED
PLAINTIFF'S REQUEST FOR PRODUCTION DIRECTED TO ALL DEFENDANTS The Plaintiff requests the Defendants, pursuant to Rule 34, Federal Rules of Civil Procedure, to produce for examination and copying at the offices of the attorney for the Plaintiff within thirty (30) days of the date of service hereof the following items: 1. Copies of all grievance files of the plaintiff, Jerome Hamilton from January 1,
1999 to the date of his release, such documents to include the grievance itself, and all documents utilizing or evidencing a response to the grievance and/or resolution of ghre grievance. RESPONSE
2.
All documents relating to, or pertaining to the calculation of the plaintiff's
release date, at any time from January 1, 1990 to the date of his release. RESPONSE
Case 1:04-cv-01422-GMS
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3.
The job descriptions of each defendant for the years 1999 through the date of
release of the plaintiff. RESPONSE
4.
Copies of documents, letters, memorandum, emails, relating to or pertaining
to the calculation of the plaintiff's release date by and among the defendants. RESPONSE
5.
Copies of documents, letters, memorandum, emails, relating to or pertaining
to the calculation of the plaintiff's release date by and between the Attorney General's Office of the State of Delaware. RESPONSE
ABER, GOLDLUST, BAKER & OVER
DATED: June 7, 2006
/s/ Gary W. Aber GARY W. ABER (DSB #754) 702 King Street, Suite 600 P.O. Box 1675 Wilmington, DE 19899 302-472-4900 Attorney for Plaintiff
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Case 1:04-cv-01422-GMS
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Filed 06/07/2006
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