Free Reply Brief - District Court of Delaware - Delaware

Case 1:04-cv-O1542—Gl\/IS ocument 111-2 - Filed 07/O9/2007 Page 1 of 2
IN TI-IE UN TED STATES DISTRICT COURT
p n FOR TH DISTRICT OF DELAWARE `
KEVIN BRATHWAITE )
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I PlaintiflQ ) E
v. g C. A. No. O4-1542-GMS
MARCELLO RISPOLI, et sl., l
Defendants.
AFFIDA OF GREGORY TURNER {
Correctional Officer Grelory Turner having been duly sworn according to law, i
deposes and states as follows: L n
l. I am employed y the State of Delaware, Department of Correction
_ (“DOC") at the Delaware Crlrrectional Center ("DCC") Smyrna, Delaware as a
Correctional Ofiicer. I connneliced employment on December 27, 2001. Among my
responsibilities are supervising 'nmates within a security location, making counts at
_ specified time periods to assure inmate location and custody, conducting searches and
sliakedowns for prohibited ite s and contraband and escorting inmates to and from
activities and work assignments. Additional duties include observing inmate activities to
detect unusual or prohibited belt `or which may be a threat to the security of the facility,
the safety ofthe inmates, employ es or visitors.
2. I make this aflidmjit based upon my personal knowledge.
3. On October 9, 20 4, a little after 9:00 AM I responded to a call for back-
up assistance from Sgt. Wallaclz in Building I'?. Inmate Kevin Brathwaite had been
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Case 1 :04-cv-01542-GIVIS ocument 1 11-2 Filed 07/O9/2007 Page 2 of 2
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unccoperative during e shakedo 11 which led Sgt. Wallace to capstun him. In an attempt
to remove him. from his cell e continued to be confrontational which resulted im.
. Brathwaite being taken tc; the ouud handcuffed and shackled. After Brethweite was 1
subdued by the officers he was trLnsferred to Building 20.
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..’ regex;} Turner
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SWORN TO AND SUBSCRIBE before me this Q day cf 3-*+ {-gz, 2007. _
Notary n -
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