IN TRB UNITED STATES DISTRICT COURT FOR THE DISTRICT
OFDHMMM3 T. f{§E@§@T 5
= ' ’ ` §yl_iU""q I
Ernest A, Crumb Jr, ) doc#5 J I
. 2 "CD 1 ITSC
v. ) C,A, Ob- 529-SLR
Robert May ) _
et al E
defendants, )
PLAINTIFFS INTERROGATORIES ~F¤2
To the defendant, Robert May,
you are hereby notified to answer under oath, the interrogatories
numbered 1 to 1h, inclusive as shown below, within 50 days of the
time service is upon you, in accordance with Rule 33 of the Federal
Rules of Civil Procedures.
Interrogatory No. 1. Is'nt it true that you filed a warrant aga-
inst the plaintiff on 08-29-O2 for escape after conviction ?.
Interrogatory No. 2.Is‘nt it true that you, along with the Emer-
gency Response Team, apprehended the plaintiff on 08-29-02 and return-
ed him back to Morris Community Correctional Center on OB-29-O2 ?.
Interrogatoby No. 5. Is'nt it true that immediately after a inmate
is apprehended on a warrant, he's suppose to be placed under arrest,
the warrant be executed and he appears beforethe nearest magistrate
available without unreasonable delay ?.
O >
Case 1:04-cv—OO329—SLR Document 16 Filed 08/O9/2005 Page 2 of 3
Interrogatory N0. Q. Is'nt it true that the nearest magistrate
available from Morris Community Correctional Center is less than 5
minutes away ?.
Interrogatory No. 5. Is'nt it true, that although the plaintiff
was returned to Morris Community Correctional Center on 08-29-02, and
remained housed at Morris Community Correctional Center until 08-50-02,
he still was'nt taken to the nearest magistrate on 08-29-02 or 08-50-02
or any other time while he was at Morris Commuuity Correctional Center ?.
Interrogatory No. 6. Is'nt it true that the plaintiff was Adminis-
tratively Transfered from Morris Community Correctional Center to Dela-
ware Correctional Center on O8=50-02 without the escape warrant being
executed ?,
Interrogatory No. 7. Is'nt it true that when a inmate is Administr-
atively Transfered to another correctional facility and will not be
returning back to the facility he was transfered from, his personal
property is suppose to be inventoried by the sending institution and
then transfered along with that inmate to the receiving institution ?.
Interrogatory No, 8, Is'nt it true that on 08-29-02 and 08-50-02,
you were Corporal Thomas Rygil's immediate supervisor ?,
Interrogatory No. 9. Is'nt it true that you did'nt stop Corporal
Thomas Rygil from taking off the plaintiff's body on 08-50-02 before
he was transfered to Delaware Correctional Center, the following items;
his 2 rings, 2 necklaces, 1 watch, 1 pair of shoes, 1 shirt, 1 belt and
pants ?.
(2)
Case 1:04-cv—OO329—SLR Document 16 Filed 08/O9/2005 Page3of3
Interrogatory No. 10; Is'nt it true that you allowed Corporal Thomas
Rygil to have the plaintiff put on Department of Corrections clothes
and sneakers after he took the plaintiffs personal property ?.
Interrogatory No, 11, Is'nt it true that none of the plaintiffs
personal property, including his Holy Quran, Kufi, Legal paperwork,
Hygenic articles or the items taken off his body by Corporal Rygil,
was transfered along with him to Delaware Correctional Center on
08-50-02 or any other time ? ,
Interrogatory No. 12. Is'nt it true that you made the decision not
to send the plaintiffs personal property along with him to Delaware
Correctional Center when he was Adminisrtatively Transfered from Morris
Community Correctional Center on 08-50-02 ?.
Interrogatory No. 15, If you answered no to interrogatory No. 12.,
then state who made that decision. If you answered yes to interrogatory
No. 12., then go to interrogatory No. 1b,
Interrogatory No, 1h, Is'nt it true that the plaintiffs personal
property, in particular, his Holy Quran, Kufi, Hygenic Articles and
his Jewelry and watch taken off his body, could have been transfered
along with him when he was Administratively Transfered to Delaware
Correctional Center on 08-50-02 ?.
Dated: 0<¤- 27 , 2005 ;; J;
Plaintiff "
Address: Delaware Corr, Center
1181 Paddock Road
Smyrna, DE 19977
Case 1:04-cv-00329-SLR
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