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

Case 1:04-cv-01417-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE RICHARD C. HUNT, Plaintiff, v. FIRST CORRECTIONAL MEDICAL SERVICES, et al., Defendants. ) ) ) ) ) ) ) ) ) )

C. A. No. 04-1417-*** JURY OF 12 DEMANDED

STATE DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS DIRECTED TO PLAINTIFF Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, State Defendants Stan Taylor, Raphael Williams and Brian Emig ("State Defendants"), through their undersigned counsel, hereby serve on Plaintiff, Richard C. Hunt, the following Requests for Production of Documents and Things. INSTRUCTIONS A. If any document or thing required to answer any Request for Production is

withheld because you claim that such information is privileged or is contained in a privileged document or communication: (1) identify each such document with sufficient specificity to permit a court to determine the propriety of the asserted privilege and setting forth the nature of the document; (2) (3) identify the privilege and set forth the factual basis for the privilege claims; and set forth each Request to which each such document or thing is responsive.

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B.

These Requests for Production are continuing in nature and, if applicable, will

require supplemental responses pursuant to Rule 26(e) of the Federal Rules of Civil Procedure. REQUESTS FOR PRODUCTION REQUEST NO. 1: 1. All grievances, complaints, or other correspondence relating to, regarding or

arising out of the incidents alleged in Plaintiff's Complaint, including, but not limited to, all grievances or complaints submitted by Plaintiff to Department of Correction personnel, responses thereto, and any related correspondence between Plaintiff and Department of Correction personnel. REQUEST NO. 2: 2. All correspondence relating to, regarding or arising out of the incidents alleged in

Plaintiff's Complaint, including, but not limited to, any correspondence between friends or family members of Plaintiff or other inmates and Department of Correction personnel. REQUEST NO. 3: 3. Any statements, declarations, petitions, or affidavits relating to, regarding or

arising out of the incidents alleged in Plaintiff's Complaint and any statements, declarations, or affidavits of Plaintiff, other inmates, or witnesses to the allegations in the Complaint. REQUEST NO. 4: 4. All criminal history records for Plaintiff from any other State besides Delaware

for the past 15 years. REQUEST NO. 5: 5. All medical records for Plaintiff relating to, regarding or arising out of the 2

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incidents alleged in Plaintiff's Complaint. REQUEST NO. 6: 6. All medical records for Plaintiff for the past 15 years.

REQUEST NO. 7: 7. Any and all document(s) referenced or identified in Plaintiff's Responses to

Interrogatories served contemporaneously herewith.

STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Eileen Kelly Eileen Kelly (I.D. 2884) Deputy Attorney General 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for State Defendants

Dated: September 4, 2007

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CERTIFICATE OF SERVICE I hereby certify that on September 4, 2007, I electronically filed State Defendants' Request for Production of Documents and Things Directed to Plaintiff with the Clerk of Court using CM/ECF. I hereby certify that on September 4, 2007, I have mailed by United States Postal Service, the document to the following non-registered party: Richard C. Hunt. /s/ Eileen Kelly Eileen Kelly (I.D. 2884) Deputy Attorney General 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for State Defendants

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