Free Interrogatories Propounded - District Court of Delaware - Delaware

Case 1:04-cv—OO329—SLR Document 18 Filed 08/O9/2005 Page 1 of 3
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IN THE UUITED STATES DISTRICT COURT FOR ·
.DISTRICT OF DELAWARE 3* g“i' “" 1 `‘ i““""1 ‘'``°‘ 1
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Ernest A, Crump Jr ) doc§5 E i 1
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Dlgintiff, ) `.`. - -· .. . .- w e l y- . -. 1 .. ....
)
v, ) C.A. OA- 529-SLR I
Robert May ) ,
et al ) i
defendants, )
PLAINTIFFS INTERROGATORIES -Hnsr set “
TO DEEHDBMNT THOMAS RYGIL
To the defendant, Thomas Rygil,
You are hereby notified to answer under oath, the interrogatories
numbered 1 to 15, inclusive as shown below, within 50 days of the
time service is upon vou, in accordance with Rule 55 of the Federal
Rules of Cuvil Procedures.
Interrogatory No. 1. Is'nt it true that you along with the Emer-
eencv Response Team, apprehended the plaintiff on OE-29-02 and ret-
urned him back to Morris Community Correctional Center ?.
Interrogatory No. 2. Is'nt it true that you, along with another
correctional officer, Administratively Transfered the plaintiff on
08-10-09 from Morris Community Correctional Center to Delaware Corr-
ectional Center ?.
C1)

j Case 1:04-cv—OO329—SLR Document 18 Filed 08/O9/2005 Page 2 of 3
H Interrogatory No. 5._Is'nt it true that on 08-50-02, you personally
took off the olaintiffs body the following items: his 2 rings, 2 neck-
laces, 1 watch, 1 pair of shoes, 1 shirt, 1 belt and pants ?.
Interrogatory N0. Q. Is'nt it true that afer you took the blaintiffs
bersonal oroberty off his body, you had him but on Deoartment of Corr-
ections clothes and sneakers ?.
Interroaatory No. 5. Is'nt it true that none of the olaintiffs
oersonal orooerty, including his Holy Quran, Kufi, Legalwork, Hygenic
articles, or the items taken off his body by you, was transfered along
with him when you administrartively transfered him to Delaware Corr-
ectional Center on 08-50-02 ?.
Interrogatory No. 6. were you ordered by a higher authority to
take the olaintiffs bersonal broperty off his body at Morris Community
Correctional center on 08-50-02 ?.
Interrogatory No. 7. If you answered yes to interrogatory No. 6,
mlease state the name of the higher authority, if you answered no to
interrogatory No. 6, then go to interrogatory No. B,.
Interrozatory No. 8. So the decision to take the blaintiffs ber-
sonal orooerty off his body was your decision ?.
Interrogatory No. 9. What did you do with the blaintifs oersonal
oroberty that you took off his body ?.
(2)

Case 1:04-cv—OO329—SLR Document 18 Filed 08/O9/2005 Page 3 of 3
Interrogatory N0. 10. On 08-10-09, did you have control and/or
nosession, at any time, over or of the Dlaintiff other oersonal oro-
oerty, in particular; his Holy Quran, his Kufi, Legalwork and Hygenic ,
articles ?.
Interrogatory No. 11. If you answered yes to interropatory No. 10,
what did you do with that oronerty ?., if you answered no to interr-
oaatory No. 10. , then go to interrogatory N0. 12.
Interrogatory No. 12. who had control of the orooerty stated in
interroaatory No. 10. ?.
Interrogatory No. 15. Is'nt it true that the olaintiffs personal
orooerty, in oarticular, his Holy Quran, Kufi, Hygenic articles, and
his iewelry and watch taken off his body bv you, could have been trans-
fered alone with him when he was administratively Transfered to Dela-
ware Correctional Center on 09-50-O? ?.
Dated: O(c>· 27 , 2005 Q CDM IE Ly
PLAINTIFF
Address: Delaware Corr. Center
1181 Paddock Road
Smyrna, Delaware 19977

Case 1:04-cv-00329-SLR

Document 18

Filed 08/09/2005

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Case 1:04-cv-00329-SLR

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Case 1:04-cv-00329-SLR

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