Free Request for Admissions - District Court of Delaware - Delaware

Case 1:04-cv-00370-SLR

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IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF DELAWARE JOHN DOHERTY, Plaintiff, v. STATE OF DELAWARE, et al., Defendants. : : : : : : : : :

C.A. No. 04-370-SLR

1st SET OF REQUESTS FOR ADMISSION DIRECTED TO PLAINTIFF Defendants request that plaintiff admit the truth of the following paragraphs within thirty days in accordance with Fed.R.Civ.P. 36. To the extent plaintiff does not provide an unqualified admission to the following paragraphs, plaintiff is requested to provide the specific reasons why an unqualified admission can not be provided as well as the identification of all individuals with knowledge, documents or tangible physical evidence that relates to such a failure to provide an unqualified admission and produce the same in accordance with Fed.R.Civ. P. 33 and 34, respectively. 1. Attached is a genuine and correct copy of a January 31, 2003 letter

from Richard E. Seifert, Deputy Bureau Chief of Prisons, to you outlining a proposal to resolve a disciplinary matter then pending against you. Response:

Case 1:04-cv-00370-SLR

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2.

Attached is a genuine and correct copy of a February 13, 2003

Agreement between you and your employer to resolve the then pending disciplinary matter against you. Response:

3.

Your employer complied with and fully performed paragraphs 1

though 5 of the February 13, 2003 agreement. Response:

4.

In paragraph 6 of the February 13, 2003 agreement, you agreed to

withdraw your current grievance and further agreed not to file any other grievances relative to the matter. Response:

5.

On June 10, 2004, you filed the present complaint against your

employer and certain fellow employees alleging the same matters that you set forth in your January 27, 2003 letter and attached petition to Chief Noreen Renard. Response:

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STATE OF DELAWARE Department of Justice

/s/ Marc P. Niedzielski Marc P. Niedzielski (# 2616) Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400

DATED: April 12, 2005

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CERTIFICATE OF SERVICE I certify that on April 12, 2005, I electronically served the attached 1St Set of Request for Admission Directed to Plaintiff on the following:

Richard R. Wier, Jr., Esquire Daniel W. Scialpi, Esquire 1220 Market Street, Suite 600 Wilmington, DE 19801 [email protected]

/s/ Marc P. Niedzielski Marc P. Niedzielski (#2616) Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 [email protected]