Lewis v. Commissioner

Filing 200

DISCOVERY ORDER (see attached) and corresponding Exhibits. Signed by Judge Charles S. Haight, Jr. on May 3, 2013. (Dorais, L.)

Case 3:03-cv-00196-CSH Document 198-1 Filed 05/02/13 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
SCOTT TALMADJE LEWIS,

:
:
:
:
:
:
:
:
:
:

Petitioner
v.
COMMISSIONER OF CORRECTION,
Respondent.

CASE NO. 3:03CV196 (CSH)

PETITIONER’S THIRD INTERROGATORIES
TO THE STATE’S ATTORNEY
Pursuant to Rule 6(b) of the Rules Governing Section 2254 Cases, Petitioner requests that
Respondent answer the following interrogatories, under oath, within ten (10) days.
If you cannot fully answer the following interrogatories, after exercising due diligence to
obtain the information to do so, please state so and answer to the extent possible, specifying your
inability to answer the remainder, and stating whatever information or knowledge you have
concerning the unanswered portions.
These interrogatories shall be deemed continuing, so as to require supplemental responses
as new and/or different information is required.
1. Was a financial reward offered by the Governor of the State of Connecticut, or another
official or agency, for information leading to the arrest and conviction of the person or
persons responsible for the deaths of Ricardo Turner and Lamont Fields?
ANSWER:

1

Case 3:03-cv-00196-CSH Document 198-1 Filed 05/02/13 Page 2 of 4

2. If such a financial reward was offered, what was the amount of that offer?
ANSWER:

3. Did Ovil Ruiz, a.k.a. Augustin Castro, at any time seek to obtain such a reward, either by
application or through other channels?
ANSWER:

4. If Ovil Ruiz made any efforts to obtain such a reward, either by application or through
other channels, state every date upon which Mr. Ruiz either applied for such a reward or
otherwise expressed his interest in receiving such a reward.
ANSWER:

5. Was Ovil Ruiz at any time told informed by a representative of the State’s Attorney or
the New Haven Police Department of the existence of such a reward?
ANSWER:

6. If Ovil Ruiz was at any time informed by a representative of the State’s Attorney or the
New Haven Police Department of the existence of such a reward, name all dates upon
which such information was provided, and for each date provide the name of the person
or persons who provided the information.
ANSWER:

2

Case 3:03-cv-00196-CSH Document 198-1 Filed 05/02/13 Page 3 of 4

7. Did Ovil Ruiz receive a financial reward for his role in facilitating the arrest and
conviction of either Scott Lewis or Stefon Morant?
ANSWER:

8. If Ovil Ruiz received a financial reward for his role in facilitating the arrest and
conviction of either Scott Lewis or Stefon Morant, on what date or dates was such a
reward distributed?
ANSWER:

9. Did any person other than Ovil Ruiz receive a financial reward for his or her role in
facilitating the arrest and conviction of either Scott Lewis or Stefon Morant?
ANSWER:

10. If Ovil Ruiz did not receive a financial reward for his role in facilitating the arrest and
conviction of either Scott Lewis or Stefon Morant, did a representative or representatives
of the State of Connecticut make a determination or determinations that Ovil Ruiz was
not entitled to such a reward?
ANSWER:

11. If a representative or representatives of the State of Connecticut made a determination or
determinations that Ovil Ruiz was not entitled to a financial reward for his role in
facilitating the arrest and conviction of either Scott Lewis or Stefon Morant, name all
dates upon which such determinations were made, and for each date provide the name of

3

Case 3:03-cv-00196-CSH Document 198-1 Filed 05/02/13 Page 4 of 4

the person or persons who made the determination, along with any reasons that were
provided for each determination.
ANSWER:

Respectfully submitted,
By ____/s/_____________________ Date: May 2, 2013
Brett Dignam
Attorney for Petitioner Scott T. Lewis
CT 00283
Morningside Heights Legal Services, Inc.
435 West 116th Street - Room 831
New York, NY 10027
212-854-4291
Fax: [phone]
Email: [e-mail]

4