Free MEMORANDUM in Support - District Court of Delaware - Delaware

_ Case‘I:O4-cv-01385-G|\/IS D0cument40-3 Fi|ed‘I1/21/2007 Page10f3

§
¤
I
I
Q
?
J
EXHIBIT B I
I N
1
4

D
2


Case 1:04-cv-01385-Gl\/IS ocument 40-3 Filed 11/21/2007 Page 2 of 3
· IN THE UNI D STATES DISTRICT COURT
FOR T DISTRICTOF DELAWARE
I Jack W. Wolf )
1 _ Plaintiff g
Q v. g C. A. No. 04-1385-GMS 1
C/O Pusey, C/O Carter and Lt. S acord 3
n Defendants ) .
AFFIDLVIT OF RAMON CARTER
I 1, Correctional Corporal 12amon Carter, having been duly sworn according to the
law, do hereby depose and state r1s follows: ‘ i
1. I am employed ivy the State of Delaware, Department of Correction
I (“DOC") at the Delaware Ccirrectional Center ("DCC") Smyrna, Delaware as a
Correctional Corporal. I cormneinccd employment on September 20, 2001. I am currently g
assigned to work the Security I-1ousing Unit SHU Building 19. In July 28, 2004, I was
assigned to building 21 in the M U.
2. I make this affida it based upon, my personal knowledge.
3. I have read Jack olt`s complaint, and I dispute his allegations. · T _
` 4. , I recall, on July , 2004, I responded to a call for assistance. I arrived at
the observation room building 2 . ‘ E E
I 5. Inmate Jack. Woli was handcuffed behind his back, yelling and shouting
profanities at the ofiicers. I r call that at one point, he charged at the Lieutenant.
Immediately I and another off} er grabbed inmate Wolf by his arms and sat him back
down to prevent him from us g his body, eg., head, feet, or weight to strike the 1
Lieutenant. U 1
. l
l
' l

Case 1:04-cv-01385-G|\/IS Document 40-3 Filed 11/21/2007 Page 3 of 3
6. Wolf was taken f m the observation room. I recall him complaining that
h could not walk. Inmate Wol stated that he could not stand, so he was placed on a
l laundry cart to wait for the nurse o arrive to exarrtine him.
5. I recall that Iamat Wolf was seen by the nurse, but she did not order that
l he stay in the intirmary. After ltis examination was completed, he stated that he was
going to "sue all you mother f kers" as he looked at our identification badges. He was I .
. dissatisfied because the nurse d`- not tell him what he wanted to hear. He acted in an
angry and hostile marutcr and rep ateclly cursed the officers.
6. At rio time did I observe any officer attack and beat Wolf Nor did I
witness him being slammed on cart, or being mishaadled by any staff while waiting for
thenurse. - I · < -..- - r
7. i”l7he-only- force as d—Jagai1=1st·i11mate··Wolf was necessary to gain c0r1trol·of
and to maintain the safety =security··of staff. · ‘ e ·i ` `e·. -·e .
. . {gm _-
A · · ‘ - I I amonC er
_ l
I — . t Q
SWORN TO AND SUBSCRIB D before me this QQ~day 0 /l/°"U£"‘*{§ , 2007. · l
I l