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Boyd-Nicholson v. Frakes

United States District Court, D. Nebraska

July 11, 2017

ARON LEE BOYD-NICHOLSON, Plaintiff,
v.
SCOTT FRAKES, Director of Nebraska State of Corrections Medical Department; DR. RANDY KOHL, Chief Medical Director, M.D.; DR. HUSTON, Staff Physician of Records; MARIO PEART, Warden; JANE OR JOHN DOE 1-12, Both state and Agency Medical Nurses; TANA KENLEY, PAC; STEPHANIE SNODGRASS, LpN; APRIL ROLLINS, RN; and CAROLYN MOORE, RN; Defendants.

          ORDER TO ALBERTO VASQUEZ SETTING FORTH THE QUESTIONS FOR A DEPOSITION BY WRITTEN QUESTIONS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 31

          RICHARD G. KOPF SENIOR UNITED STATES DISTRICT JUDGE.

         ALBERTO VASQUEZ, you have been identified as a possible witness in this case.

         IT IS ORDERED that you follow the instructions set forth below.

         INSTRUCTIONS AND QUESTIONS

         You are herewith ordered to answer the following written questions but only if you have personal knowledge of the facts responsive to the question.

         If you do not have personal knowledge of the facts do not answer any question for which you lack personal knowledge. Simply leave the space for your answer blank and answer the other questions. When answering the questions, do not seek assistance from any other person including, but not limited to, ARON LEE BOYD-NICHOLSON. The answers must be your own.

         Answer the questions in your own handwriting. Please print your answers carefully and legibly.

         Once your case manager or other official serves this document upon you, you have seven calendar days to complete the document. After you are done, notify your case manager or other official. You will then appear before a notary public at the prison, and sign the document under oath. Please remember that your answers must be truthful and will be given under penalty of perjury.

         1. How long have you had diabetes?

         2. How long have you been going to medical for your diabetic checks?

         3. How long have you been going to diabetics here at LCC?

         4. Is it your recollection that the LCC medical staff would possess records of your visits as a diabetic to medical? [If you can answer this question, you must also write the basis for your answer.]

         5. From your experience of going to diabetics at LCC, are there unscheduled visits by inmates to the medical clinic that have been sent to medical in the past with the diabetics? [If you can answer ...


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