Free Answer to Interrogatories - District Court of Delaware - Delaware

Case 1 :04-cv-00329-SLR? Document 28-__“Fi-led 12/19/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ERNEST CRUMP, JR. )
Plaintiff, g
v. i C.A. No. O4-329-SLR
ROBERT MAY, THOMAS RYGIL, l
VINCE BIANCA, and STAN TAYLOR, )
Defendants.
DEFENDANT OFFICER THOMAS RYGHRS I RESPONSE TO PLAINTIFF’S
FIRST SET OF INTERROGATORIES
State Defendant, Officer Thomas Rygil responds to Plaintiffs First Set of
Interrogatories as follows:
l. Isn’t it true that you along with the Emergency Response Team, apprehended
the plaintiff on 08-29-02 and returned him back to Morris Correctional Center?
ANSWER: No.
2. Isn’t it true that you, along with another correctional officer, Administratively
Transferred the plaintiff on 08-30-02 from Morris Community Correctional
Center to Delaware Correctional Center?
T ANSWER: No.
3. Isn’t it true that on 08-30-02, you personally took off the plaintiffs body the
following items: his 2 rings, 2 necklaces, 1 watch, l pair of shoes, 1 shirt,
lbelt and pants?
ANSWER: No.
4. Isn’t it true that after you took the plaintiff s personal property off his body,
‘ Plaintiff misspelled Defendant Thomas Rygil’s name throughout this doeument. The proper spelling is
"Thomas Rygiel“.

Case 1 :04-cv-00329-SLR Document 25 Filed 2/19/2005 Page 2 of 4
you had him put in Department of Corrections clothers and sneakers?
ANSWER: No.
5. Isn’t it true that none of the plaintiffs personal property, including his holy
Koran, Kuti, Legalwork, Hygenic articles, or the items taken from his body by
you, was transferred along with him when you administratively transferred him
to Delaware Correctional Center on 08-30-O2'?
ANSWER: No.
6. Were you ordered by a higher authority to take the plaintiffs personal property
off his body at Morris Community Correctional Center on 08-30-O2?
ANSWER: No.
7. lf you answered yes to interrogatory No. 6. then go to interrogatory NO. 8.
ANSWER: N/A
8. So the decision to take the plaintiffs personal property off his body was your
decision?
ANSWER: No.
9. What did you do with the plaintiffs personal property that you took off his body?
ANSWER: It is denied that I personally took anything off the Plaintiffs body.
Upon information and belief detainee and offender personal property is sent to the
inmate property room upon entry to a DOC facility.
10. On 08-30-02, did you have control and/or possession, at any time, over or of the
plaintiff other personal property, in particular; his Holy Koran, Kuti, Legalwork
and Hygenic articles?
ANSWER: No.

Case 1 :04-cv-00329-SLR Document 25 Filed 12/19/2005 Page 3 of 4
l 1. If you answered yes to intrrogatory No. 10, what did you do with that property?
If you answered no to interrogatoiy No. 10, then go to interrogatory no. 12.
ANSWER: N/A.
12. Who had control of the propeity stated in interrogatory No. I0?
ANSWER: I have no personal knowledge.
13. ISI1’t it true that the plaintiffs personal property, in particular his Holy Koran,
Kufi, Legalwork, Hygenic articles, and his jewelry and watch taken off his body by
you, could have been transferred along with him when he was administratively
transferred to Delaware Correctional Center on 8-30-O2?
ANSWER: It is denied that I took any personal property from the Plaintiff. Inmate
property is not sent with an inmate who is being administratively transferred as a
result of an escape warrant.
of
SWORN TO AND SUBSCRIBED before me this ,day of Dlééwrlsmq
zoos.

Case 1:04-cv-00329-SLR Document 25 Filed 12/19/2005 Page 4 ot 4
CERTIFICATE OF SERVICE
I hereby certify that on December 19, 2005, I electronically filed State Dejerzdant
Thomas Rygiel 's Answers to Plaintws First Set of 1nterrogatorie.v, with the Clerk of Court
using CM/ECF. I hereby certify that on December 19, 2005, l 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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