Free Answering Brief in Opposition - District Court of Delaware - Delaware

_ Case 1 :04-cv-01378-GMS Document 41 -4 Filed 09/27/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SAAD M. SOLIMAN, ) I ·\ _` - A
) ` ,
Plaintiff`, ` ) , ` ` — _
J
v. ) Civil Action No. 04-1378 (GMS)
) `\
STANLEY TAYLOR; PAUL HOWARD; ) . I · ’ I
THOMAS CARROLL; LAWRENCE ) J URY TRIAL DEMANDED
McG·UIGAN; JAMES LUPINETTI; DAVID E. ) i I
PIERCE, Jr.; JOSEPH BRICHARDSON; ) `
RONALD HOSTERMAN; CERTAIN )
UNKNOWN INDIVIDUAL EMPLOYEES OF )
THE DELAWARE DEPARTMENT )
OF CORRECTION; and STATE OF ) `
DELAWARE DEPARTMENT OF )
CORRECTION, )
)
Defendants. )
AFFIDAVIT OF SAAD SOLIMAN
I, Saad Soliman, being duly sworn according to law, hereby depose and say as follows:
I. I am the Plaintiff in the above-captioned matter.
2. I have reviewed the Amended Complaint and Plaintiffs Answering Brief. All of
the averments in the Amended Complaint and the Statement of Facts in the Answering Brief are
true and accurate to the best of my knowledge.
3. I have read the Affidavit of Corporal Lise Merson which was submitted in support
of Individual State Defenda.nts’ Opening Brief in Support of Their Motion to Dismiss/Surnrnary
Judgment Pursuant to Rules I2(b)(1), 12(b)(6), and 56(c).
4. Contrary to Corporal Merson’s statement, I tiled many more grievances during
2004 than the grievances that she identified in her statement. In fact, I tiled thirteen grievances
during that year.
5. The grievances that she failed to mention were grievances that were filed while I
was housed in "The Hole" and in maximum security.
1

Case 1:04-cv-01378—G|\/IS Document 41-4 Filed 09/27/2005 Page 2 of 2
6. The grievances that I filed while in "The Hole" and maximum security were in
reference to:
(l) the beating that I suffered on May l2, 2004;
(2) being put in "The Hole” for a violation that I did not commit;
(3) not being given a hearing within fifteen days of being placed in "T he Hole";
(4) violations of my right to free speech;
(5) violations of my right to freedom of religion;
(6) racial discrimination;
(7) religious discrimination;
(8) being removed from my job at DelDOT;
(9) not being given my Commutation of Sentence Hearing;
(10) being denied rehabilitation programs; and
(1 I) being denied medical care
7. While housed in “Thc Hole" and in maximum security, the extent to which I was
able to personally tile these grievances was to simply hand them to my corrections officer.
8. All ofthe above mentioned grievances were not addressed by DOC, DCC or
anybody.
s Soliman
SWORN TO AND SUBSCRIBED before
this _ • y of February, 2005
. ..
EG,;;*‘ 91/ M
JEFFREY K. MARTIN, Esc:.
not/my auauc
r;~ .i.A.w/ -g._ v.-»rr‘s‘onMrav
ww.
2