Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00023-SLR Document 21 Filed 01/14/2008 Page 1 of 2
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January 14, 2008
Robert D. Brown
SBI #23 1393
Howard R. Young Correctional Institution
P.O. Box 9561
Wilmington, DE 19809
RE: Robert D. Brown v. Wilmington Police Officers Rinehart and Drysdale
C.A. No. 07-023 SLR
Dear Mr. Brown:
In accordance with the Court’s Order of December 12, 2007, enclosed are the documents in
Defendants’ possession which are responsive to your Motion to Compel Discovery.
1. Wilmington Police Department Defensive Tactics Report dated April 16, 2006;
2. Wilmington Police Department Initial Crime Report dated April 16, 2006;
3. Handwritten notes of Defendant Drysdale;
4. Christiana Care Health Services - Wilmington Hospital Discharge Instructions dated
April 16, 2006;
5. Wilmington Police Department - Directive 7.9 - Use of Force;
6. Wilmington Police Department Police Officer’s Manual Index. Although you have
requested the entire Manual, it is over 500 pages and many of the Directives are
irrelevant and would not lead to the discovery of relevant information. As such,
Defendants obj ect to the production ofthe entire Manual. However, I have enclosed
the Manual index. Should you determine that there are other Directives other than
Directive 7.9 - Use of Force, which I have enclosed, please advise me and I will
provide them to you should they fall under the applicable Rules of Discovery . `

Case 1 :07-cv-00023-SLR Document 21 Filed O1/14/2008 Page 2 of 2
Robert D. Brown;
January 14, 2008
Page 2 _
Regarding your request that the Defendants’ subpoena your witness, Ms. Grier, please be
advised that the subpoenaing of your witness is your responsibility not the Defendants.
b §`ncer ly,
A Ro ` asso
.1 First Assistant City Solicitor
Enclosures
cc: Clerk of Court (w/encl.)