Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1:04-cv-00175-JJF Document 161-9 Filed 06/20/2008 Page 1 of 3
EXHIBIT H

Case 1:04-cv-00175-JJF Document 161-9 Filed 06/20/2008 Page 2 of 3
\ CONNOLLY BOVE LODGE Be HUTZ LLP
A ATTORNEYS AT LAW
WILMINGTON, DE
Brian R. Lemon _ _
TEL (302) 8886319 TTIS NEITIOLITS Btllldlhg
FAX (302) 658-6246 1007 North Orange St.
Et‘$t‘r‘?l2"l3l‘.%.$§§.°€.'£‘... mg;tjj¤gE 19899
TEL: ooziysss 9141
FAX: (302) 558 5614
May 7, 2008 WEB; www.¤blh.<:om
VIA FACSIMILE AND U.S. MAIL
Daniel A. Griffith, Esquire
Whiteford Taylor & Preston
1220 N. Market Street
Suite 608
Wilmington, DE 19801
Re: Curgg v. Hopkins fC.A. 1:04-CV-00175-JJF)
Dear Daniel:
_ On May 5, 2008, we received the Defendant’s responses to the Plaintiffs
Second Set of interrogatories (Nos. 1-10). This letter illustrates defects in some
of the responses. Please supplement the following responses in the manner
described without further delay.
lnterrogatory No. 6: This interrogatory requests specific facts about the
Defendant’s employment at Sugarloaf Farms, including dates of employment and
the names of co-workers. None are provided. Please supplement your response
without further delay.
lnterrogatory No. 7: This interrogatory asks for a description of every instance in
which the Defendant has been accused of police brutality, etc. ln response, the
. Defendant only refers to documents regarding the arrest of Reginald Jenkins.
Defendant does not describe this specihc instance. Also, no other instance is
mentioned. Since no objection to this request was made, we will assume there
has been no other instance. Please supplement your response without further
delay.
lnterrogatory No. 8: This interrogatory seeks an explanation of the proper
procedure in using a K-9 unit during the arrest or apprehension of a suspect. ln
response, the Defendant purports to have provided a copy of the Dover Police
Department’s polices and procedures to the Plaintiff in November 2005.
However, no manuals or procedures have ever been produced. Further, no _
explanation of the proper procedures is given. Please supplement your e
response without further delay.
WILMINGTON, DE WASHINGTON, DC LOS ANGELES, CA

Case 1:04-cv-00175-JJF Document 161-9 Filed 06/20/2008 Page 3 of 3
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Da11ie1A. Griffith, Esquire
May 7, 2008
Page 2
lnterrogatory No. 9: This interrogatory seeks the identity of persons who have
knowledge of the allegations stated inthe Plaintiffs amended complaint. The
Defendant failed to properly identify any person. The definition of "identify" found
in the Plaintiffs Second Set of interrogatories sets forth information needed to
fully respond to this interrogatory, including, but not limited to, names, titles and
addresses. Please supplement your response without further delay.
lnterrogatory No. 10: The Defendant simply responds to this interrogatory by
stating "To be provided? The Defendant did not seekan extension of time in
which to respond to this interrogatory. Please supplement your response without
further delay.
Sincerely,
Brian R. Lemon
cc: Scott E. Swenson, Esquire
l\/lr. Joseph Curry


Case 1:04-cv-00175-JJF

Document 161-9

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Case 1:04-cv-00175-JJF

Document 161-9

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