Free Motion for Reargument - District Court of Delaware - Delaware

Case 1:04-cv—O1391-JJF Document 106-4 Filed 06/O3/2008 Page 1 013
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Case 1 :04-cv-01391-JJF Document 106-4 Filed 06/03/2008 Page 2 of 3 e E
12;*1 B.r"2BQ7 14: so tsnzsessssv LEGAL seieutciie Peet; @2x 3 ·
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IN THE UNITED STATES DISTRICT COURT
IN AND F0 THE DISTRICT OF DELAWARE
rmornor WARD, )
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Plaintifi; ) g
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v. ) Q
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STANLEY TAYLOR, et. at., ) C. A. No. 04-1391 *** l
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Defendants/Third Party ) `
Plaintiffs, ) ,
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FIRST CORRECTIONAL MED CAL ) `
DELAWARE, LLC, J ) - ,
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'l`l1ir·d··Party efcndant. ) E I
I Ai`iidgLi[ of Lieutenant Paul Harvey E
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l. I have been employed bi the State of Delaware Department ol? Correction since | l
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December, 1993. I currently hcl the position of Correctional Lieutenant at the Delaware I
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Correctional Center (DCC), an have held this position since approximately October 1, ,‘
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2000. I leit the employment o the Dcpartrnent of Correction for a one year period of i I
approximately Oct. 1, 2004 until August 2i, 2005, to work as a police ofliccr for the City
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of Milford. I was rehired by D C. on approximately August 21, 2005. i
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2. I recall an incident whic occurred on July 10, 2004, in which an inmate, who I §
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am told was Timothy Ward, wires assaulted by another inmate. I had no personal l
lmcwledge ofthe incident itself} but I did take pictures of Mr. Ward’s irjuries after the ’ 4
assault when he was in the infi ary. `
3. I did not find out that Ti othy Ward had filed a .lawsuit until May of 2007, when c
an attorney from the Department of Jusrlce met with me to discuss my recollection ofthe _ I


Case 1 :04-cv—01391-JJF Document 106-4 Filed 06/03/2008 Page 3 of 3 i
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matter. I was told that I was just a possible witness, not a defendant, in the matter. I have
never read Mr. Ward’s lawsuit d ain not aware of who all ofthe defendants are. ll
4. I had no reason, at any “ e, to believe that I would ever be named as a defendant
in this lawsuit. I do not know hy Mr. Ward would want to name me as a defendant at i
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as it nsmsmssnso har on one ?' say or ,2007,
personally appeared before me, Jhe Subscriber, a Notary Public for the State and County
aforesaid, PAUL HARVEY, w o, being by me duly sworn according 1:o law did depose i
and say that the foregoing state. ent is correct to the best of his knowledge, information l
and eater. ‘
PAUL var 1
SWORN TQ) AND SUBSCRIBE before me on this day of ®·¤<'¤»··6¤¤. 2007. / I
Noi agar l I
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