Free Response to Motion - District Court of Delaware - Delaware

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12;1Bf2@@7CaiLs1é313:04-ci/?i02IEI?§§I§°.I.lF ocument QSLEGAL I§ll;<§drIl?§/50/2007 Page 1 of 2P"5'GE @2 E3 i
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IN THE UN. TED STATES DISTRICT COURT
IN AND FO THE DISTRICT OF DELAWARE
TIMOTHY WARIL ) i
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Plaintiff, )
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V. )
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STANLEY TAYLOR, et. al., ) C. A. N0. 04-1391 ***
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Defendants/Third Party )
Plaintiffs, )
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v. A )
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FIRST CORRECTIONAL MED CAL ) l
DELAWARE, LLC, J ) »
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Third-Party cfcndant. ) Q
AffidaLit of Lieutenant Paul Harvey
1. I have been employed biL the State of Delaware Department of Correction since
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December, 1993. I currently hcl the position of Correctional. Lieutenant at the Delaware `
Correctional Center (DCC), and have held this position. since approximately October 1, ,
2000. I left the employment o the Department of Correction for a one year period of
approximately Oct. I, 2004 until August 21, 2005, to work as a police officer for the City
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ofMilfo1Sd. I was rehired by D C on approximately August 21, 2005.
2. I recall an incident whic occurred on July l0, 2004, in which an inmate, who I
am told was Timothy Ward, »i·as assaulted by another inmate. I had no personal
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knowledge of the incident itself, but I did take pictures of Mr. Ward’s injuries after the '
assault when he was in the iniii ary.
3. I did. not find out that Ti othy Ward had filed a lawsuit until May of 2007, when e
an attorney from the Department of Justice met with me to discuss my recollection ofthe l
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miSim?cd§ié31@;04-eiiibigaidi Ei] F ocumeni 9s?5G’°"‘ i§iE§gI`i:5/$0/2007 Page 2 or 2’°"i‘GE Z3" @3
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matter. I was told that I was just a possible witness, not a defendant, in the matter. I have I
never read Mr. Ward’s lawsuit am not aware of who all ofthe defendants are.
4. I had no reason, at any t' e, to believe that I would ever be named as a defendant
in this lawsuit. I do not know hy Mr. Ward would want to name me as a defendant at
this time. j
aa IT REMEMBERED Ira on as _/ Ԥf' day of ,2007,
personally appeared before me, ine Subscriber, a Notary Public for the State and County
aforesaid, PAUL HARVEY, wlio, being by me duly sworn according to law did depose
and say that the foregoing stateriient is correct to the best of his lmowledge, information
and belief. l
D .
PAUL aver
SWORN TQ) AND SUBSCRIBE before me on this day of ®·r¤=»·—6¤¢t 2007. /
Not @57
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