Free Initial Disclosures - District Court of Delaware - Delaware

Case 1:04-cv-01529-KAJ

Document 25

Filed 08/30/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) Plaintiff, ) ) v. ) ) WARDEN RICK KEARNEY, ) COMMISSIONER STANLEY TAYLOR, ) and CHIEF BUREAU OF PRISONS ) PAUL W. HOWARD, ) ) Defendants. ) KENDALL GUINN,

C. A. No. 04-1529-KAJ

INITIAL DISCLOSURES PURSUANT TO FED. R. CIV. P. 26(a) Pursuant to Fed. R. Civ. P. 26(a), State Defendants Warden Rick Kearney, Commissioner Stanley Taylor and Bureau Chief Paul Howard hereby provide Plaintiff with the following information: (a) Individuals likely to have knowledge of discoverable information that may be used to support State Defendants' defenses: Plaintiff Defendants Inmates housed in the Medium Housing Unit, Sussex Correctional Institution, Georgetown, DE Captain George Truitt, Sussex Correctional Institution, Georgetown, DE Eric Smeltzer, Sussex Correctional Institution, Georgetown, DE (b) Documents that may be used to support State Defendants' defenses: Maintenance/repair records for the Medium Housing Unit at Sussex Correctional Institution Inmate grievances regarding the Medium Housing Unit Responses to Inmate grievances regarding the Medium Housing Unit

Case 1:04-cv-01529-KAJ

Document 25

Filed 08/30/2005

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(c) Experts and their opinions: Defendants have not yet retained any experts, but reserve the right to do so, and will supplement this response as required by Rule 26(a). (d) Insurance agreements in force: Not applicable. State Defendants further disclose that no such insurance exists. (e) Basis for any damages claimed: Not applicable. By these disclosures, State Defendants do not represent that they have identified every document, tangible thing or witness possibly relevant to this lawsuit. Continuing investigation and discovery may require modification of these disclosures, and State Defendants reserve the right to supplement the information disclosed above if additional information becomes available. Further, these disclosures are not intended to waive any right to object to the production of any document or tangible thing disclosed on the basis of privilege, the work product doctrine, relevance, undue burden or any other valid objection. STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Eileen Kelly Eileen Kelly, I.D. #2884 Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for State Defendants Date: August 30, 2005

Case 1:04-cv-01529-KAJ

Document 25

Filed 08/30/2005

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CERTIFICATE OF SERVICE I hereby certify that on August 30, 2005, I electronically filed Initial Disclosures Pursuant to Fed. R. Civ. P. 26(a) with the Clerk of Court using CM/ECF. I hereby certify that on August 30, 2005, I have mailed by United States Postal Service, the document to the following non-registered party: Kendall Guinn.

/s/ Eileen Kelly Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected]