Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1:04-cv—01523-JJF Document 32-6 Filed 08/17/2007 Page1 0f3
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Case 1:04-cv—01523-JJF Document 32-6 Filed 08/17/2007 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBBIE D. JONES, )
Plaintiff, g
v. 3 C.A. No. 04-1523-JJF
COMMISSIONER STAN TAYLOR, 5
WARDEN RICK KEARNEY, )
SGT. BARRY BILES, and TIANA )
BANKS, )
Defendants. g
AFFIDAVIT OF DAVID SEYMORE
l. I am employed by the State of Delaware, Department of Correction at the
Sussex Correctional Institution ("SCI."), in Georgetown, Delaware as a Correctional
Officer. I have been employed by the Department of Correction for _,__l0w__ years.
2. I was contacted by the Deputy Attorney General defending this matter in
regards to an allegation that I observed and intervened in an incident between Sergeant
Biles and Inmate Jones on July 6, 2004. I do not recall observing or intervening in any
incident between Sgt. Biles and Inmate Jones on July 6, 2004, or on any other date.
3. I also did not write an incident report for an incident between Sgt. Biles
and Inmate Robbie Jones on July 6, 2004. If I had observed any incident involving the
use of force, I would have written an incident report pursuant to SCI’s Standard
Operating Procedures. My name also would have been included on the report of Sgt.
Biles or on the report of any officer who wrote a report in relation to the incident. i
4. I have made these statements based upon my personal knowledge,
specialized training, and experience as an employee of the Department of Correction.
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Case 1:04-cv—01523-JJF Document 32-6 Filed 08/17/2007 Page 3 of 3
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David Seymo
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SWORN AND SUBSCRIBED before me this 2 day of August, 2007. E0
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Notary {

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