Free Motion for Reargument - District Court of Delaware - Delaware

Case 1:04-cv-01391-JJF Document 112-2 Filed 08/12/2008 Page 1 0f 3
EXHIBIT 1

Case 1 :04-cv-01391-JJF Document 112-2 Filed 08/12/2008 Page 2 of 3
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IN THE TED STATES DISTRICT COURT l
INAND FU THE DISTRICT OF DELAWARE
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Plaintiff} ) g.
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v. } I
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STANLEY TAYLOR, et. al., ) C. A. No. 04-1391 ***
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Defendants/Third Party ) l
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FIRST CORRECTIONAL MED CAL )
DELAWARE, LLC, ) .
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Third-Party efcndant. ) n I Q
U Afii i of Lieutenant Paul Howe E
1. I have been employed bi the State of Delaware Depesrtrnent of Correction since 1 i
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December, 1993. I currently hel the position of Correctional Lieutenant at the Delaware { l
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P C¤¤¤<=ti¤¤e1 Center (DCC), an have hcid this position since approximately October 1, _P
2000. I left the employment o the Departrment of Correction for a one yam period of |
approximately Oct. I, 2004 until August 2t, 2005, to work as at police officer- for the City t
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of Milford. I was reliired by D C. on approximately August 2t , 2005. i
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2. I recall an incident whie occurred on July 10, 2004, in which an inmate, who I
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. _ nm told wes Timothy Ward, Les assaulted by another inmate. I had no personal { l
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knowledge ofthe incident itself} but Idid take pictures of Mr. Ward’s injuries after the ` l
assault when he was in the im U . g `
3. . I did not End out that T` cathy Ward had filed it lawsuit until May of 2GO?, when ·
on attorney litem the Department of Justice met with me to discuss my recollection of the I

Case 1 :04-cv-01391-JJF Document 112-2 Filed 08/12/2008 Page 3 of 3
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matter. I was told that I was just a. possible witness, not s defendant, in the matter. I have
never reed Mr. Ward’s lawsuit d am not aware of who all of the defendants ere. I-
4. Ihad no reason, et any ` e, to believe that I would ever be named as s. defendant ` I _
in this lawsuit. I do not Ituow by II/ir. Ward would want to name me es a defendant at I
this time. I`
· BE ITREMEMBERED he on this if 57 day or 2007,
psrsonaliy appeared before. me, Ihe Subscriber, a Notary Public for the State and County
aforesaid, PAUL HARVEY, w o, being by me duly sworn according to law did depose
and say that the foregoing state out is correct to the best of his knowledge, information I
ssa better, ‘
PAUL to-ar I
I SWORN TI} AND SUBSCRIBE before me on this day of ¤I}·e¤·¤.-BM., 2007. I I
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