Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1 :04-cv-01250-SLR Document 12-3 Filed 06/29/2005 Page 1 of 2
IN TI-IE UNITED STATES DISTRICTCOURT
FOR Tim DISTRICT OF DELAWARE
ERNEST BROOKINS, )
Plaintiff, g
v. g CA. No. 04—l250·~SLR
RAPHAEL WILLIAMS, g
)
Defendant. g
AFFIDAVIT OF ANN DOWNEY
I, Ann Downey, having been duly sworn according to the law, do hereby depos and state
the foilowing:
1. I ani employed bythe State of Delaware, Department of Correction, at the Howard R.
Young Correctional.}- Irzstzitution (“HRYCI") in Wiixnington, Delaware as an Administrative
Speciaiist I!]. I have been employed by the Department of Correction for 25 years. My duties
include ch-zrical support for the office of the Warden. I have held this position since
Aprit 9, 1936.
2. hi response to a request from the State of Delaware Department of Justice, I have
obtained doctnnentation relating to the medical records of pre-trial detainee Ernest Broolrins,
from July 7, 2004, the date he entered }RYCI to September 1, 2004, the date he was released.
3. I have received the medical records from Denise Gallier, First Correctional Medical
Director of Operations on or about May 20, 2005.
4. I sent ali the medical records that Ireceived, to the State of Delaware Department of
Justice, on or about May 20, 2005.
5. I have not changed or altered the records that I received in any way, before sending them

Case 1:04-cv-01250-SLR Document 12-3 Filed 06/29/2005 Page 2 of 2
to the State of Delaware Deparhnent of Justice.
6. I have made these statements contained in this affidavit based upon my personal
knowledge, training, and experience as an employee of the State of Detaware Department ot`
Correction.
Amt Bewney S
SWORN TO ANI) SUBSCRHBEB BEFORE ME THIS <9? BAY OF E Lygh/___(,__ , 2005.
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