Free Reply Brief - District Court of Delaware - Delaware

Case 1:04-cv-00370-SLR Document 23-2 Filed 08/26/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
JOHN DOHERTY, :
Plaintiff]
v. C.A. N0. 04-370-SLR
STATE OF DELAWARE,
DEPARTMENT OF CORRECTION, :
NOREEN RENARD, JOSEPH :
PAESANI, JAMES LUPINETTI, :
MICHAEL TIGUE, and ROBERT I. :
GEORGE, JR., :
Defendants.
DECLARATION OF PHILLIP E. MORGAN
I, Philip E. Morgan, do state under the penalty of perjury that the foregoing
is true and correct pursuant to 28 U.S.C. § l'/46.
1. I am employed by the Delaware Department of Correction and have
been so employed since 1975. Presently, I am the Warden of the Plummer
Community Corrections Center, on Todd’s Lane, Wilmington, Delaware.
2. The plaintiff, John Doherty, through his supervisor Michael
Cocuzza, reports to me.
3. The plaintiff has never requested reimbursement (in writing) for
parking expenses involving his travel to the New Castle County Courthouse.
Generally, employees arrange for other employees to shuttle them to the
Courthouse.

Case 1:04-cv-00370-SLR Document 23-2 Filed 08/26/2005 Page 2 of 2
4. The plaintiff has not requested requalification to carry a firearm by
filling a form for that purpose through this office. The requalification procedures
are well known and are scheduled on an ongoing basis for many employees.
Phillip E. Morgan

Case 1:04-cv-00370-SLR

Document 23-2

Filed 08/26/2005

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Case 1:04-cv-00370-SLR

Document 23-2

Filed 08/26/2005

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