Free Answer to Interrogatories - District Court of Delaware - Delaware

1 1,@g,2B@5Casqg::,514-cv-00329-SLR Document 25 I liiled 12/19/2005 Page 1 of 4 NU- 232 W2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ERNEST CRUMP, JR )
Plaintiff, g
v. l C.A. No. 04-329-SLR
ROBERT MAY, THOMAS RYGIL, g
VINCE BIANCA, and STAN TAYLOR, )
Defendants. l
DEFENDANT VINCENT BI@CA’S IQSPONSE T0 [LA[N"I`I[[’S
_lj§l_§T SET OF IQ IQRROGATORIES
State Defendant, Vince Bianco responds to P1a.intifi’ s First Set of Interrogatories as
follows: ’
1. Isn ‘t it true that when the Plainiiffwas apprehended on 8.29.02 by Robert May,
Thomas Rygil and the Emergency Response Team and returned to Morris Community
Correctional Center, you were there upon h.is arrival or arrived shortly thereafter his
a1‘1‘iva1?
ANSWER: I was on the grounds ofthe facility when the plaintiff was 1'etumed from
escape status.
2. lsn’t it true that by your order and directive on 8-3-02 the Plaintiff was
administratively transferred from Morris Community Correctional Center(MCC) to
Delaware Correctional Center?
g§§WER: The Plaint" was transferred to the Delaware Correctional Center on the
strength of an emergency capias and active warrant for escape after conviction.
‘ Plaintiff misspelled Defendant Vince Biancvs name throughout this document. The proper spelling is
"Vince Bior•co“.
l

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3. lsn‘t it true that Robert May tiled and obtained a warrant on 8.29.02 for the
Plaintiffs arrest for escape aiter conviction?
@SW’ER: I do not know who obtained the warrant for escape after conviction.
4. Isn’t it une that even though the plaintiff was apprehended by Robert May, Thomas
Rygil and the Emergency Response Team on 8.29.02 said warrant was not executed until
9-05-O2'?
gill SWEE: I do not know when the warrant was executed.
5. Isn’t it true that on 8.30.02 the day ofthe P1iljHlLiH° s administrative transfer to D.C.C.
he had not been ofncially charged with escape?
g§SWER: See answer #2.
6. Isn’t it true that since the Plaintiff was a resident at Morris Community
Correctional Center at thc time ofthe escape warrant, and was returned back to the center
5` hours later, and spent the night and also the partial momiug of the next day there, and
was that technically, he was still a resident at your center when you administratively
transferred to D. C.C. on B.30.02‘?
I do not understand the question.
7. Isn’t it true, that whenever a inmate is transferred to another correctional facility
and will not bc returning back to the facility he was transferred nom, all his property,
including his Koran and Kuti, which allows him to exercise his religion, is suppose to be
inventoried by the sending institution and then transferred along with that itunate to the
receiving institution?
&ljSWER: In the event of a scheduled transfer, personal items src sent with the
offender. Should the offender escape from custody, staff secure items abandoned by the

11/@9’2B@5 Case'51€0’4-cv—00329-SLFl Document 20--I- Fil-ed 12l19/2005 Page 3 of 4 Nll.232 U 4
offender and store same for a minimum of 30 days before donating same to charity.
8. Isn’t it true that when the Plaintiff was transferred from the Morris Community
Correctional Center on 8.30.02 to Delaware Correctional Center, none of his persons]
property, including his Holy Koran and Kutl were transferred along with him. nor came
at a latter date?
g§ SWER: I have no idea what personal property if any the plaintiff possessed.
9. Isn’t it true that you received 2 letters from the Plaintiff, one dated 9.12.02 and the
other dated 9.22.02, in reference to his personal property being transferred along with
him izrom Morris Community Correctional Center to Delaware Correctional Center?
ANSWEQ: I do not recall receiving correspondence from the otfender dated 9.12.02. or
9.22.02.
10. isn’t it true that you never corresponded back to the plaintiff in reference to his 2
letters sent to you about his property? '
ANSWER: Ido not recall receiving correspondence from the oEender dated 9.12.02. or
9.22.02.
ll. lsn’t it true that the plaintiff s personal property, at very least, his Holy Koran
and Kufi could have been transferred along with him when you had him adrnirristratively
transferred to D.C.C. on 8.30.02?
: see Answer # 7
l Vincent Bianca
2005 SWORN TO AND SUBSCRJBED before me this A day of , ZOO S,


Case 1:04-cv-00329-SLR Document 28 Filed 12/19/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on December 19, 2005, I electronically tiled State Defendant
I Vincent Bianco ’s Answers t0 Pluintifs First Set oflnterrogcttories, with the Clerk of Court
using CM/ECF. I hereby certify that on December 19, 2005, 1 have mailed by United States
Postal Service, the documents to the following non-registered participant: Ernest A. Crump, Jr.;
SBI #149221; Delaware Correctional Center; 1181 Paddock Road; Smyrna, DE 19977.
STATE OF DELAWARE
DEPARTMENT OF JUSTICE
/s/ Ophelia M. Waters
Ophelia M. Waters
Deputy Attorney General
820 North French Street, 6th Floor
Wilmington, Delaware 19801
(302)577-8400
[email protected]

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