Free Request for Admissions - District Court of Delaware - Delaware

Case 1 :04-cv—00328-SLR Document 35 Filed 10/26/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ERNEST CRUMP, JR. )
Plaintiff, l
v. l C.A. No. 04-328-SLR
STAN TAYLOR, THOMAS CARROLL, l
CORRECTIONAL MEDICAL SERVICES, )
DAVID DUNNINGTON, and MICHAEL )
BRYANT, )
Defendants. )
STATE DEFENDANT THOMAS CARROLL’S REPONSE TO PLAINTIFF’S
FIRST REQUEST FOR ADMISSIONS
State Defendant Thomas Carroll responds to the Plaintiffs First Request for
Admissions as follows:
l. On August 30, 2002, the Plaintiff was transferred from the Delaware
Correctional Center receiving room to the Delaware Correctional Center
Hospital, and placed in a room commonly known as the "RAM Room".
ANSWER: Upon infomation contained in plaintiffs institutional records Defendant
admits plaintiffs allegations in paragraph l.
2. Plaintiff remained in said room Ram Room until September 3, 2002.
ANSWER: Upon information contained in plaintiffs institutional records Defendant
admits plaintiffs allegations in paragraph 2.
3. Plaintiff was stripped totally naked after entering said room on August 30,
2002.
ANSWER: Upon infomation contained in plaintiffs medical records Defendant
admits plaintiffs allegations in paragraph 3.

Case 1:04-cv-00328-SLR Document 35 Filed 10/26/2005 Page 2 of 4
4. Plaintiff was given two pieces of paper towel type material for clothing while
he was housed in the RAM ROOM.
ANSWER: Upon information contained in plaintiff" s medical records, Defendant admits
the medical records reflect that the medical staff provided Plaintiff a paper hospital gown
while on suicide watch.
5. The Ram Room has a toilet that is a hole in the floor.
ANSWER: Upon information and belief Defendant admits that in 2002, the toilet in the
suicide observation room was recessed into the floor to prevent inmates from using the
toilet to harm self, e.g. drowning, or others, e.g. ripping the toilet from the wall.
6. The Ram Room has no running water.
ANSWER: Upon information and belief Defendant admits plaintiff"s allegation that
in 2002, the room had no running water.
7. The Ram Room has a metal bed with no bedding material including no mattress.
ANSWER: Upon information and belief Defendant denies plaintiff’ s allegations in
paragraph 7.
8. The Ram Room has a cement slab on the floor for a bed with no bedding material,
including no mattress.
ANSWER: Upon information and belief Defendant denies plaintiff s allegations in
paragraph 8.
9. The Ram Room has no toilet paper in said room.
ANSWER: Upon infomation and belief Defendant denies plaintiff’s allegations in
paragraph 9.

Case 1:04-cv-00328-SLR Document 35 Filed 10/26/2005 Page 3 of 4
10. The Ram Room’s toilet cannot be flushed from inside said room by the inmate.
ANSWER: Upon information and belief Defendant admits in 2002 inmates could not
manually flush the toilet and did not have control of the water to prevent the inmate from
flooding the room and the tier.
lhomas Carroll, Warden DCJ
SWORN TO AND SUBSCRIBED before me this Q { day of October, 20 .
° 4
Notary .

Case 1:04-cv-00328-SLR Document 35 Filed 10/26/2005 Page 4 of 4 p
CERTIFICATE OF SERVICE
I hereby certify that on October 26, 2005, I electronically filed State Defendant
Thomas Carroll ’s Responses to Plointyfs First Request for Admissions with the Clerk of
Court using CM/ECF . I 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; 1181 Paddock Road;
Smyrna, De 19977.
STATE OF DELAWARE
DEPARTMENT OF JU STICE .
fsf 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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