Free Request for Admissions - District Court of Delaware - Delaware

. Case 1:05-cv-00102-SLR-LPS Document 103 _Fi|ed O1/O4/2007_ Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SHAMSIDIN Ati, a/k/a/ Roster ) `
seunntns, g
Pieietitt, )
V, g I Civil Action No. 05-102-MPT
PAUL HOWARD, et al., i
Defendants. ) E S JAN_i4ZmH g I
. REQUEST FOR ADMISSIONS if-
V..1o .. T A E I
Pursuant to Rule 36, Fed. E. Civ. P., plaintiff request thatwiml .
I defendant Stan Taylor make the following admission within 30 days
after service of this request.
1. Between January 2005 and December 2006, was outbreak of
Methicillin—Resistant Staphylococcus Aureus (MSRA) at Delaware
2 cerreetienei Center ("ncc").
2. Plaintiff contacted via mail, concerning-lack of treatment
by medical provider concerning lack of treatment for MRSA on
number of occassions.
3. Each facility within Delaware Department in compliance
with standards set by American Disabilities Act.
A. Department of Corrections has administrative procedures
govening housing inmates with physical disibilities. I
5. Department of Corrections has administative procedures_ .
governing transporting inmates with physical disabilities.
6. You ordered transfer of plaintiff from Sussex Correctional
Institution ("SCI"). - -
7. Plaintiff brought to your attention, issues concerning
improper expenditure from inmate commissary account at SCI. `
8. Plaintiff instituted investigation by Civil Rights Division
A — U.S. Justice Department while housed at SCI.
9. Plaintiff contacted Robert Wagner, State Auditor, concerning
questionable expenditures from inmate commissary account at SCI.

_, Case 1:05-cv-00102-SLR-LPS Document 103 Filed O1/O4/2007 Page 2 of 4
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10. Inmates assigned building 21 - DCC, provided three
(3) hours exercise per week.
11. Inmates housed in building 21 — DCC fed in their cells.
12.- When inmates depart building 21 - DCC, secured with
waist chains and leg shackles.
13, Plaintiff suffers with various medical disabilities.
14. Plaintiff walks with assistance of cain.
15. Cains not permitted in building 21 — DCC.
16. Plaintiff's medical records accompanied him when transferred {
from SCI. 1
17. You are familiar with management of methicillian-resistant
staphylococcus aureus infection (Federal Bureau of Prison - Clincial
Practice Guidelines, August 2005).
18. Warden Thomas Carroll - DCC informed you of outbreak of MRSA.
19. Inmates assigned DCC required to utilize wheelchairs, cains,
crutches, required to wait in rain, snow and extremely hot weather
prior going too mess hall.
n 20. Inmates assigned wheelchairs, required to depend on other .
inmates in going—to various points within DCC.
21, Plaintiff was assigned—upper-#%—totairtime house in building
21 - DCC. I _
22, Within building 21 — Dcc is a handicapped cell.
23. You were aware plaintiff being constantly fed cold food
1 while housed in building 21.
24. Inmates physical conditions, not considered when transferred 1
from on housing unit to another.
24. Correctional Medical Systems, advised your office of MRSA
outbreak at DCC. ‘
25. You would sanction correctional staff fabicrating rule
infractions on inmate.

. Case 1:05-cv-00102-SLR-LPS Document 103 Filed O1/O4/2007 Page 3 of 4
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26. Plaintiff requested be permitted hire polygraph examiner .
minus any cost too department. I
27. You can authorize inmate to have polygraph examination
conducted within departments facilities.
28. Plaintiff transferred from SCI for disciplinary reasons.
29. The department does not have written polich for housing
physically incapacitated inmates.
30 The department has within facilities, hospice program
_ according Title 11 Section 3536(c). ` .
31. There no longer outside agency, providing monitoring for :
inmate grievance system. 1
32, Plaintiff housed at SCI ten (10) years.
33. If classified plaintiff could return SCI, with same security
classification status.
34. Plaintiff been incarcerated thirty (30) years.
35. There exist disparity in application in classification .
of black and white inmates.
36. There is not one black inmates serving either life or P
life without parole sentences, working in "Concete Design Systems"
at DCC. ‘
37. The majority of minual inmate jobs, held by minority in-
mates at DCC and SCI. l
38. Plaintiff has been constant advocate for minority inmate
rights . .
T l {
SHAMSIDIN ALI, 052590
1181 Paddock Road — DCC.
Smyrna, DE 19977
DATED: December 29, 2006
CERTIFICATE OF SERVICE
I HEREBY CERTIFY copy of aforemention furnished Kevin K. Connors,
Esquire, P.0. Box 8888, Wilm, DE 19899, and Elieen Kelly Deputy Attorney
General, Carvel State Office Bldg., 820 N. French St., Wilm, DE. By
U.S. Mail this 29th day of december 2006 with sufficient postaged
affixed thereto.
SHAMSIDIN ALI, 052590

Case 1:05-cv-00102-SLR-LPS Document 103 Filed O1/O4/2007 Page 4 of 4
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