Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1:04-cv—01523-JJF Document 32-5 Filed 08/17/2007 Page1 0f3
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ei/Ibizdgg-JJF D¤e5iiiei#ibL2FsEmEl=a|ea oe/17/2007 Rage 2 er 3 I °°1
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBBIE D. JONES, )
Plaintiff, I
v. g C.A. No. O4-1523-JJF
COMMIS SIO '>IER STAN TAYLOR, I
WARDEN R] SK KEARNEY, ) -
SGT. BARRY BILES, and TIANA ) ‘
BANKS, )
Defendants. I U
n AFFIZDAVIT OF TIANA BANKS
1. 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 hai ·e been employed by the Department of Correction for ten (10) years.
` 2. I have reviewed Plaintift`s Complaint and dispute the allegations therein.
3. On July 6, 2004, Sergeant Biles called Inmate Jones to his office. I
opened the gate and let Inmate Robbie Jones off the tier. After opening the gate and
letting Inmate Jones off of the tier, I did not remain but returned to the tier. I did not
observe any · ncident between S gt. Biles and Inmate Jones on July 6, 2004.
4. 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 forc :, 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.
i Bi.les or on toe report of any officer who wrote a report in relation to the incident.
5. I have made these statements based upon my personal knowledge,
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specialized tra; ning, and experience as an employee of the Deparmmnt of Ccrrechcn.

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Tiana Banks
[ S i
SWG} IN AND SUBSCRIBED before me this % day of August, 2007.
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