Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1:06-cv-00368-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WONELL RINGGOLD Plaintiff, v. CORRECTIONS OFFICER LAMBEY Defendant. ) ) ) ) ) ) ) ) )

C.A. No. 06-368-SLR JURY TRIAL DEMANDED

DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS DIRECTED TO PLAINTIFF Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendants, through their undersigned counsel, hereby serve on Plaintiff, Wonell Ringgold, the following Requests for Production of Documents and Things. INSTRUCTIONS A. If any document or thing required to answer any Request for Production is

withheld because you claim that such information is privileged or is contained in a privileged document or communication: (1) identify each such document with sufficient specificity to permit a court to determine the propriety of the asserted privilege and setting forth the nature of the document; (2) identify the privilege and set forth the factual basis for the privilege claims; and (3) set forth each Request to which each such document or thing is responsive. B. These Requests for Production are continuing in nature and, if applicable,

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will require supplemental responses pursuant to Rule 26(e) of the Federal Rules of Civil Procedure.

REQUESTS FOR PRODUCTION REQUEST NO. 1: 1. All grievances, complaints, or other correspondence relating to, regarding

or arising out of the incidents alleged in your Complaint, including, but not limited to, all grievances or complaints submitted by you to Department of Correction personnel, responses thereto, and any related correspondence between you and Department of Correction personnel. REQUEST NO. 2: 2. All correspondence relating to, regarding or arising out of the incidents

alleged in your Complaint, including, but not limited to, any correspondence between you and your friends or family members or other inmates and Department of Correction personnel. REQUEST NO. 3: 3. Any statements, declarations, petitions, or affidavits relating to, regarding

or arising out of the incidents alleged in your Complaint and any statements, declarations, or affidavits of Plaintiffs, other inmates, or witnesses to the allegations in the Complaint. REQUEST NO. 4: 4. All of your medical records relating to, regarding or arising out of the

incidents alleged in your Complaint. REQUEST NO. 5:

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5.

All of your medical records for the past 15 years.

REQUEST NO. 6: 6. All of your criminal history records from any other State besides Delaware

for the past 15 years. REQUEST NO. 7: 7. All documents requested to be identified or referenced in your Response

to Defendants' First Set of Interrogatories, served contemporaneously herewith.

DEPARTMENT OF JUSTICE STATE OF DELAWARE /s/ Stacey Xarhoulakos Stacey Xarhoulakos (I.D. 4667) Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendant

Dated: December 14, 2007

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CERTIFICATE OF SERVICE I hereby certify that on December 14, 2007, I electronically filed Defendant's Request for Production of Documents and Things directed to Plaintiff with the Clerk of Court using CM/ECF. I hereby certify that on December 14, 2007, I have mailed by United States Postal Service, the document to the following non-registered party at both listed address: Wonell Ringgold SBI #00382856 HRYCI P.O. Box 9561 Wilmington, De 19809 and 510 Buttonwood Street Wilmington, DE 19801 /s/ Stacey Xarhoulakos Stacey Xarhoulakos (I.D. 4667) Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendants