Free Response to Discovery - District Court of Delaware - Delaware

Case 1:05-cv-OOO37—SLFl Document 126 Filed O9/24/2007 Page 1 of 4
17868/363581
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HARRY L. SAMUEL, )
) C.A. No. 05-037- SLR
Plaintiff, )
) JURY OF l2 DEMANDED
v. )
)
WARDEN THOMAS CARROLL, et al., )
)
Defendants. )
DEFENDAN T FIRST CORRECTIONAL MEDICAL’S g"ANSWERING
DEFENDANT’S") RESPONSES TO PLAINTIFF’S
SUPPLEMENTAL DISCOVERY REQUESTS
l. Plaintiff requests the name(s) of the dentists and dentist assistant that examined
plaintiff s dental problem(s) claimed in compliant nom 9/1/2004 to 6/30/2005?
(10/7/2004).
RESPONSE: Georgianna Mickens, dental assistant; Kathy Kionke, dentist and
dental director.
2. State the reason why plaintiffs dental treatment was delayed for 8 to 9 months and
state the name of the person that authorized plaintiffs treatment to be delayed for 8 to 9
months.
RESPONSE: The person who stated that it would be an 8 to 9 month delay was
Kathy Kionke, D.D.S. She was the Dental Director. Inmates are seen based on
priority and whether the health of the inmate would be adversely impacted.
Plaintiff was housed in the Maximum Security Unit. It is more difficult for the
prison system to transfer inmates to the main facility where the dentist is located

Case 1 :05-cv-OOO37—SLFl Document 126 Filed O9/24/2007 Page 2 of 4
17868/363581
because only a few maximum security inmates can be transported at a time and
because maximum security inmates must be segregated from all other inmates.
3. State if the following individuals was First Correctional Medical staff, Hom
9/3/2004 to 6/30/2005.
7 Wolken, Gina
c. Munson, Amy
d. Lyons, April
e. Rickards, Suesann
f Merson, Lisa M.
g. lf FCM staff state each staff member title and duty in regard to claim
presented in complaint?
li. State if any of the above individuals examined the plaintiff? H
RESPONSE: The following employees that worked for answering defendant
were: Gina Wolken, Facility Operations Supervisor who oversaw the Medical &
Dental Unit in regards to complaint issues; Amy Munson, Health Administrator
who oversees the entire Medical & Dental Units in all capacities; April Lyons,
Health Administrator for Gander Hill receiving training from Amy Munson;
Suesann Rikards, Health Administrator for Sussex Correctional was at DCC to
assist Amy Munson with facility issues. None of the above individuals examined the
plaintiff.

Case 1 :05-cv-00037-SLR Document 126 Filed O9/24/2007 Page 3 of 4
17868/363581
HECKLER & FRABIZZIO, P.A.
/s/ Gerald J. Hager
Daniel L. MoK.enty, DE Bar N0. 2689
Gerald J. Hager, DE Bar N0. 4097
The Corporate Plaza
800 Delaware Avenue, Suite 200
P.O. Box 128
Wilmington, DE 19899-0128
[email protected]
302—573—4800
Attorneys for Defendant
First Correctional Medical

Case 1 :05-cv-00037-SLR Document 126 Filed O9/24/2007 Page 4 of 4
17868/363581
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HARRY L. SAJVIUEL, )
) C.A. No. 05-037- SLR.
Plaintiff, )
) JURY OF 12 DEMANDED
v. )
)
WARDEN THOMAS CARROLL, et al., )
)
Defendants. )
CERTIFICATE OF SERVICE
I certify that, on September 24, 2007, copies of Defendant First Correctional
Medical 's Responses to Plaint@"s Szavplemental Discovery Requests were served upon
the following individuals:
Via Electronic Service y
Ophelia Waters, Esquire
Department of Justice
820 N. French Street
6th Floor
Wilmington, DE 19801
Via First Class Mail
Hairy L. Samuel
SBI# 201360
Delaware Correctional Center
1181 Paddock Road
Smyrna, DE 19977
/s/ Gerald J. Hager
Gerald J. Hager, DE Bar No. 4097