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

Case 1:04-cv-01392-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WALLACE E. HARDEN, Plaintiff, v. GOVERNOR RUTH ANN MINNER, ET AL., Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 04-1392-JJF

DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS DIRECTED TO PLAINTIFF WALLACE HARDEN Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendants, through their undersigned counsel, hereby serve on Plaintiff, Wallace Harden, 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.

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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 your Complaint, including, but not limited to, all grievances or complaints submitted by you to Department of Correction personnel, responses thereto, and any related correspondence between you and Department of Correction personnel. REQUEST NO. 2: 2. All correspondence relating to, regarding or arising out of the incidents alleged in your Complaint, including, but not limited to, any correspondence between you and your friends or family members 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 your Complaint and any statements, declarations, or affidavits of other inmates or witnesses to the allegations in the Complaint. REQUEST NO.4: 4. All of your medical records relating to, regarding or arising out of the incidents alleged in your Complaint. REQUEST NO. 5: 5. All of your medical records for the past 15 years. REQUEST NO. 6: 6. All of your criminal history records from any other State besides Delaware for the

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past 15 years. REQUEST NO. 7: 7. All documents requested to be identified or referenced in your 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: February 22, 2008

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CERTIFICATE OF SERVICE I hereby certify that on February 22, 2008, I electronically filed Defendants' Request for Production of Documents and Things Directed to Plaintiff Wallace Harden with the Clerk of Court using CM/ECF and I hereby certify that I have mailed by United States Postal Service, the document to the following non-registered party: Wallace Harden SBI # 146818 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977

/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