Free Request for Admissions - District Court of Delaware - Delaware

liv Case 1:05-cv-00102-SLR-LPS Document 110 Filed 01/30/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT 0F DELAWARE
srmnsiniw ALI, a/k/a/ Rosrnr ) _
saunnrns, g ,
Piannitr, g 1
v. ) Civil Action No. O5-102-MPT
)
PAUL HOWARD, et al., % 7 I
_ I Defendants. )
REQUEST FOR ADMISSIONS l
Pursuant to Rule 36, Fed. Ri. Civ. P., plaintiff request that 1
defendant Crystal Austin make the following admissions within 30 E
days after service of this request.
1. Have bachelor's degreein nursing.
U 2. Registered nurse. ·
3. Have associated degree in nursing. ,
4. There are written policys and procedures by Correctional l
Medical Service, for handling communicable and infectious diseases.
5. Plaintiff designated chronic care.
6. Treated plaintiff for skin infection. Liv? _;j g“wm_mg“~
7. Have received trainin in treatment-of methicilillih— &g$
resistant staphylococcus aureus ("MRSA"). 5 j““`“**E=,5
8. Conducted follow-up on plaintiff's skin infectionl- 4 EQ lQ7W
9. Recommended plaintiff's case to physician. J 4Q gf fir
10. MRSA can cause permanent disfigurment, and death.li;j 0* ,g;l
ll. Unfamiliar with the diagnosis and treatment of MRSArl gg f€n»
12. Cultured plaintiff's skin infection. U l §lJwKimJF%§ _T_
13. Gave plaintiff keflex for skin infection. Em l
1é. Consulted physician concerning plaintiff's skin iniE;$;;7:““;’J
fection. ` g
15. There are effective antibiotices for threatment of MRSA.
16. Have State of Delaware nursing license.
17. Failure to culture pplaintiff°s skin infection, resulted l
in not receiving curremt prescribed treatment. A
18. Care provided plaintiff accepted standard of care for
MRSA.

_ Case 1:05-cv-00102-SLR-LPS Document 110 Filed 01/30/2007 Page 2 of 2
;2 T". -
19. Plaintiff treated for spider bite.
20. MRSA is transmitted from person to person by
- containated hands.
21. MRSA infection cannot be clinicall distinguished `
from staphylococcal infection, that are sensitive to beta-
lactam antibiotics.
22. MRSA infection are diagnosed by routine aerobic
baterical cultures.
23- Diagnosing plaintiff's infection and culturing could
. determin plaintiff’s risk too others.
24. Inmate with suspected or confirmed MRSA infection
should be systematically tracked.
` 25. Delaware Correctional Center use the MRSA Case Tracking ·
and Reporting forms.
26. Prescribed treatment follow—up for plaintiff.
27. Consulted infectious disease specialitis concerning
plaintiffs skin infection.
28. Have been fired from medical related employment.
29. Employed by other health related agencies.
‘ 30. Prescribed medication for plaintiff°s skin infection.
7 t ,.... VW?
‘
ROBERT SAUNDERS ,
· 1181 Paddock Road —.DCC ‘
Smyrna, DE 19977 _
DATED: January 26, 2007 .
CERTIFICATE OF SERVICE
I HEREBY CERTIFY copy of the aforementionfurinshed Kevin J.
Connors, Esquire, P.O. Box 8888, Wilm, DE 19899-8888, and
Elieen Kelly, Deputy Attorney General, Department of Justice,`
Carvel State Office Building, 820 N. French Street, Wilm, DE 19801.
By U.S. Mail this 26th day of January 2007 with sufficient postage
affixed thereto. ,_h i
SHAMSIDIN ALI, 052590