IN THE UNITED STATES DISTRICT COURT
FOR TI-IE DISTRICT OF DELAWARE
ERNEST CRUMP, IR. )
Plaintiff g
v. g C.A. No. O4-329-SLR
ROBERT MAY, THOMAS RYGIL, l
VINCE BIANCA, and STAN TAYLOR, )
Defendants. g
DEFENDANT VINCE BIANCA’S1 RESPONSE TO PLAINTIFF’S
REQUEST FOR ADMISSIONS
State Defendant, Vince Bianco responds to Plaintiffs Request for Admissions as
follows:
1. Defendant Robert May was on duty at Morris Community Correctional Center on
the evening of August 29, 2002, between the hours of 4:00 PM. and Midnight.
Admitted.
2. Defendant Robert May was on duty at Morris Community Correctional `
Center(MCC) on the moming of August 30, 2002, between the hours of 12:00
AM. until the time the Plaintiff was transferred irom MCC to the Delaware
Correctional Center(DCC)
3. Defendant Thomas Rygil was on duty at the Morris Community Correctional
Center the evening of August 29, 2002 , between the hours of 4:00 PM and
midnight,
: Admitted.
ca's name. The proper spelling is “Bi.a¤co"
11/eo/2oes Case$%1o04—cv-00329-SLR in Document 2; iiFiIed 12/19/2005 Page 2 of 4 No. 232 one
4. Defendant Thomas Rygil was on duty at Morris Community Correctional Center
on the morning of August 30, 2002, between the hours of 12:00 A.M until the
time the Plaintiff was transferred from Morris Community Correctional Center to
Delaware Correctional Center on August 30, 2002.
RESPONSE: Admitted.
5. Defendant Vince Bianca was on duty or retumed back to duty at MCC on the
evening of August 29, 2002, after the Plaintiff was returned to said center on
August 29, 2002.
RESPONSE: Admitted.
6. Defendant Vince Bianca was on duty cr returned to duty at Monis Community
Correctional Center on the morning of August 30, 2002, between the hours of 12:00
AM. until the time the plaintiff was transferred {rom Morris Community Correctional
Center to Delaware Correctional Center on August 30, 2002.
RESPONSE: Admitted.
7. None of the Plaintiff’ s personal property including Koran and Kuft were
inventoried and transferred along with him to Delaware Correctional Center on
August 30,2002.
RESPONSE: Defendant Bianco is without sufficient knowledge or information
to admit this averment.
8. Defendant Vince Bianca received a letter from the plaintiff dated 9.12.02 in
reference to his personal property, including his Koran and Kun, not being transferred
along with him to Delaware Correctional Center.
QQSPOQSQ: I do not recall receiving correspondence from the offender dated
11/B9/EBBECGSBET @4-cv-00329-SLR Docutnetit 27 i Filed 12/19/2005 Page 3 of 4 NEL232 DB.?
9.12.02. ·
9. Defendant Vince Bianca received a letter from the plaintiff dated 9.12.02 in
reference to his personal property, including his Koran and Kun, not being transferred
along with him to Delaware Correctional Center.
RESPONSE: This request is redundant. See response to #8.
10. Defendant Vince Bianca never corresponded back to the plainti£f’ s letters dated
9.12.02 and 9.22.02.
RESPONSE: Ido not recall receiving correspondence from the offender dated
9.12.02 or 9.20.02
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Case 1:04-cv-00329-SLR Document 27 Filed 12/19/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on December 19, 2005, I electronically filed State Defendant
Vincent Bianco ’s Responses to Piainty‘j"s First Request For Admissions, with the Clerk of Court
using CM/ECF. I hereby certify that on December 19, 2005, I 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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