Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1:04-cv-01523-JJF

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Filed 05/03/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ROBBIE D. JONES, Plaintiff, v. COMMISSIONER STAN TAYLOR, WARDEN RICK KEARNEY, SGT. BARRY BILES, and TEANNA BANKS, Defendants. ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 04-1523-JJF

DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendants, through their undersigned counsel, hereby serve on Plaintiff, Robbie Jones, the following Requests for Production of Documents and Things. INSTRUCTIONS A. If any document or thing required to answer any Request for Production is

withheld because you claim that such information is privileged or is contained in a privileged document or communication: (1) identify each such document with sufficient specificity to permit a court to determine the propriety of the asserted privilege and setting forth the nature of the document; (2) (3) B. identify the privilege and set forth the factual basis for the privilege claims; and set forth each Request to which each such document or thing is responsive. These Requests for Production are continuing in nature and, if applicable, will

require supplemental responses pursuant to Rule 26(e) of the Federal Rules of Civil Procedure. 1

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REQUESTS FOR PRODUCTION REQUEST NO. 1: 1. All grievances, complaints, or other correspondence relating to, regarding

or arising out of the incidents alleged in Plaintiff's Complaint, including, but not limited to, all grievances or complaints submitted by Plaintiff to Department of Correction personnel, responses thereto, and any related correspondence between Plaintiff and Department of Correction personnel. REQUEST NO. 2: 2. All correspondence relating to, regarding or arising out of the incidents

alleged in Plaintiff's Complaint, including, but not limited to, any correspondence between friends or family members of Plaintiff or other inmates and Department of Correction personnel. REQUEST NO. 3: 3. Any statements, declarations, petitions, or affidavits relating to, regarding

or arising out of the incidents alleged in Plaintiff's Complaint and any statements, declarations, or affidavits of Plaintiff, other inmates, or witnesses to the allegations in the Complaint. REQUEST NO. 4: 4. All medical records for Plaintiff relating to, regarding or arising out of the

incidents alleged in Plaintiff's Complaint. REQUEST NO. 5: 5. All medical records for Plaintiff for the past 15 years.

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REQUEST NO. 6: 6. All criminal history records for Plaintiff from any other State besides

Delaware for the past 15 years. REQUEST NO. 7: 7. All documents identified or referenced in Plaintiff's Response to

Defendants' First Set of Interrogatories, served contemporaneously herewith.

DEPARTMENT OF JUSTICE STATE OF DELAWARE /s/ Stacey Xarhoulakos Stacey Xarhoulakos (I.D. 4667) Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendants

Dated: May 3, 2007

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CERTIFICATE OF SERVICE I hereby certify that on May 3, 2007, I electronically filed Defendants' Request for Production with the Clerk of Court using CM/ECF. I hereby certify that on May 3, 2007, I have mailed by United States Postal Service, the document to the following non-registered party: Robbie Jones SBI # 313356 Sussex Correctional Institution P.O. Box 500 Georgetown, DE 19947

/s/ Stacey Xarhoulakos Stacey Xarhoulakos (I.D. 4667) Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected] Attorney for Defendants

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