Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case1:04-cv-01523-JJF Document 32-13 Filed 08/17/2007 Page10f3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBBJEZ D. JONES, )
Plaintiff} I
v. g C.A., No. O4-} 523—.I.IF
COMMISSIONER STAN TAYLOR, i
WARDEN RICK KEARNEY, )
SGT. BARRY BILES, and 'I`1QANA )
BANKS, )
Defendants.
` AFHDAVIT OF MIKE DE OY `
I, Mike Deloy, having been duly sworn by law, do hereby depose and state as follows:
i. I am employed by the State of Delaware Department of Correction (“DOC”) as
Warden at the Sussex Correctional Institution (“SCI"). I have been employed by the DOC since
. November of 1.980 and as Warden of SCI since May of 2007. Prior to that, I held the position of `
Deputy Warden of SCI from October of 1996.
2. At the request of the Deputy Attorney Generai detending this matter, 1 had the
personnel tile of Sergeant Barry Biles reviewed for disciplinary history. Sergeant Bilcs has been
working at SCI since 1998 and-has no record of being disciplined whiie at SCI in his personnel tile,
including any record for assaulting an inmate.
3. All correctional officers are required to participate in a rigorous eight-week training
program prior to becoming officers. This program includes basic defense training and training on the
use of force module. Officers are then required to participate in a refresher cotuse once every year
on the use of force module. I
4. Standard Operating Procedures at SCI and the Bureau of Fr-isons Policy and


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Procedures require that officers wnte an lnerdent Report when they effect or witness an incident {
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involving the use of force. These procedures also require that when writing such report, the offi cers {
include the names of any other ofricers or inmates who were present and may have effected or {
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witnessed the incident.
5. I have made these statements based upon my personal knowledge, specialized
training, and experience as an employee ofthe Department of Correction.
‘ Mike Deloy
{ 'i '1 ‘ V A · ` - V _ _ _ V
SWORN AN D bUBbC.RIBED before me ttus gg day of August, 2007.
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