Free Reply Brief - District Court of Delaware - Delaware

Case 1 :04-cv-00921-SLR Document 89-5 Filed 10/O2/2006 Page 1 of 2
IN THE [HYITED STATES DISTRICT COURT
FOR TI-IE DISTRICT OF DELAWARE
VURNIS L. GILLIS, ]
Plaintiff, l
3 Civil Action No. 04-921-KA.]
v.
l
STAN TAYL011, er ai., )
Defendants. I
AFFIDAY [jj OF LATISIHA J QHNSO§
I, Latisha Jolmaou, having been duly sworn by law, do hereby depose and
state as follows:
1. I am employed by Correctional Medica] Services ("CMS") in the
Medical Records Departtttextt located at the Delaware correctional Center.
2. In late July, early August 2006 I was asked to make a copy of the
entire medical H1: of Inmate Vumis Gillis, SBI #00180180.
3. As requested, I made a copy of all of Gil1is’s available medical
Eles and seat the copied files for mailing.
4. On or about August 4, 2006 I spoke with Deputy Attomey General
Erika Y. Treas regarding the Gillis medical files. I conveyed to DAG Tross that I had
copied all of Crillis's available medioal Hies and that there were no additional documents
or iles for Gillis.

Case 1 :04-cv—OO921-SLR Document 89-5 Filed 10/O2/2006 Page 2 of 2
7. In addition I called the medical departments at the Secured
Housing Unit and the Maximum Housing Unit. I was told tl1at the medical tiles I had
contained all of the available records for Gillis and that there were no other available
records. I
S. After reviewing the files I contacted DAG Trees and told her that I
had sent her a cc py of all ef Gillis’s available medical files and that there were no records
c,....... it Medica me uaaag nom wee to me mid lvvlls.
9. Accordingly, I certify that all available medical records indexed to
Gillis have been provided to DAG Treas. .

Latisha o sen
SWURN AND SUBSCRIBED before me this 5.76*5% day cf .r _-
_, 2006. ;;;_r_t~;.A_
No ’
.. 2 - Q