Free Request for Production of Documents - District Court of Delaware - Delaware


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Date: June 7, 2006
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State: Delaware
Category: District Court of Delaware
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Case 1:04-cv-01422-GMS

Document 42

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

Document 42

Filed 06/07/2006

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