Free Response to Discovery - District Court of Delaware - Delaware

Case 1 :04-cv—00328-SLR Document 36 Filed 10/26/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ERNEST CRUMP, JR. )
Plaintiff, g
v. g C.A. No. 04-328-SLR
STAN TAYLOR, THOMAS CARROLL, l
CORRECTIONAL MEDICAL SERVICES, )
DAVID DUNNINGTON, and MICHAEL )
BRYANT, )
Defendants. )
STATE DEFENDANT STANLEY TAYLOR’S RESPONSE TO PLAINTIFF’S
DISCOVERY REQUEST
State Defendant Stanley Taylor by and through undersigned counsel responds to the
Plaintiffs Discovery Request as follows:
l. All instructions promulgated by the Department of Corrections in
connection with the placement of an inmate in the RAM ROOM, or
whatever other said room it is known by.
ANSWER: Defendant objects to the request to the extent that it seeks documents
or information protected from disclosure by statute. Without waiving this
objection refer to medical documentation previously provided.
2. An incident report, if any, or any other documentation indicating what
happened, if anything at Delaware Correctional Center Receiving Room
on 08-30-02 in reference to the plaintiff
ANSWER: Refer to the incident report and medical records previously provided.
3. Transfer documentation of plaintiff being transferred on 08-30-02 irom
Delaware Correctional Center Receiving Room to the RAM Room

Case 1 :04-cv—00328-SLR Document 36 Filed 10/26/2005 Page 2 of 4
ANSWER: Refer to the incident report and medical records previously provided.
4. Transfer documents from Delaware Correctional Center Ram Room to
Delaware Correctional Center Pre-Trial.
AN SWER: Refer to the incident report and medical records previously provided.
5. The name of the female Correctional Officer at the Delaware Correctional
Center hospital on 08-30-02 that had the plaintiifo into the Ram Room on that
day-referred to in this complaint as Jane Doe#l.
ANSWER: Defendant objects to the request on the grounds that it is overly
broad, unduly burdensome, and vague. Without waiving the objection, Defendant
has produced the incident report and medical records.
6. The name of the Watch Commander and/or Shift Commander who worked
at Delaware Correctional Center on 08-30-02 and was there at Delaware
Correctional Center when the plaintiff was transferred from Delaware
Correctional Center Receiving Room to the Ram Room referred to in this
complaint as John Doe #4.
ANSWER: Refer to the incident report and medical records previously provided.
7. A Blueprint and/or diagram of the Ram Room at Delaware Correctional
Center or whatever other name it is known by.
ANSWER: Defendant objects to the request to the extent that it seeks documents
or information protected from disclosure by statute, and is beyond the scope of
Federal Rules of Civil Procedure 26 (b) (l) as it is unlikely to lead to the
discovery of relevant admissdale information.

Case 1:04-cv-00328-SLR Document 36 Filed 10/26/2005 Page 3 of 4
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Stanl Taylor, El. ` sioner DOC
SWORN TO AND SUBSCRIBED before me thisdg day of October, 2005.
Notary F -
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As to objections:
STATE OF DELAWARE
E ARTM_ T OF JUSTICE
3* Y ’
I helia M. aters, ID# 3879
eputy Attomey General
820 N. French Street, 6th Floor
Dated: October , 2005 Wilmington, DE 19801
Counsel for Defendant

Case 1:04-cv-00328-SLR Document 36 Filed 10/26/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on October 26, 2005, I electronically tiled State Defendant
Stanley Taylors ’s Response to Pfaintyfs Discovery Request with the Clerk of Court
using CM/ECP . 1 hereby certify that on October 26, 2005, I have mailed by United
States Postal Service, the document to the following non-registered participant: Ernest A.
Crump, Jr.; SBI#149221;Delaware Correctional Center; 118l Paddock Road; Smyrna, De
19977.
STATE OF DELAWARE
DEPARTMENT OF JUSTICE
/s/ Ophelia M. Waters
Ophelia M. Waters, ID#3879
Deputy Attorney General
820 N. French St., 6th Floor
Wilmington, DE 19801
(302)577—8400
[email protected]

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