IN THE UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

BOBBI BOLTON,

Plaintiff,

vs. CASE NO. 4:03cv307-RH/WCS

UNITED STATES OF AMERICA,

Defendant.

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DEFENDANTS’ FIRST REQUEST FOR ADMISSIONS

COMES NOW the Defendant, by and through counsel, Assistant

United States Attorney, Robert D. Stinson, pursuant to Fed. R.

Civ. P. 36, and requests Plaintiff to admit the following

matters. If you deny any statement, state the facts on which

your denial is based.

1. Admit that Bobbie Bolton was incarcerated at the Federal

Correctional Institution, Tallahassee, Florida from October

30, 2001 through October 1, 2002.

2. Admit that Bobbie Bolton shared a cell at FCI Tallahassee

with inmate Natasha Johnson during the period from May 9,

2002 through August 7, 2002.

3. Admit that inmate Celeste Wells was housed in the same unit

as plaintiff Bobbie Bolton at FCI Tallahassee from July 26,
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2002 through August 7, 2002.

4. Admit that inmates at FCI Tallahassee can communicate with

Bureau of Prisons staff through various means.

5. Admit that inmates at FCI Tallahassee can communicate with

Bureau of Prisons staff in writing.

6. Admit that inmates at FCI Tallahassee can communicate with

Bureau of Prisons staff verbally.

7. Admit that Bureau of Prisons staff at FCI Tallahassee are

available to inmates 24 hours a day.

8. Admit that from December 12, 2001 through October 1, 2002

plaintiff Bobbie Bolton’s case manager was T. Williams.

9. Admit that plaintiff Bobbie Bolton was assigned a Unit Team

that consisted of a Case Manager, Correctional Counselor and

a Unit Manager.

10. Admit that plaintiff Bobbie Bolton had the ability to make

contact with and communicate with members of her Unit Team

while she was incarcerated at FCI Tallahassee.

11. Admit that plaintiff Bobbie Bolton was involved in the

Residential Drug Treatment program at FCI Tallahassee.

12. Admit that Drug Treatment Program staff are available to

inmates in the unit where the Residential Drug Treatment

program is conducted at FCI Tallahassee.

13. Admit that inmates can speak to prison staff about issues of

concern during mainline at the noon meal.
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14. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that

Officer Linton was making inappropriate comments to her.

15. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that

Officer Linton made inappropriate physical contact with her.

16. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that

Officer Linton touched her in any sexual manner. 

17. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that

Officer Linton had sexual intercourse with her. 

18. Admit that the Bureau of Prisons Standards of Employee

Conduct prohibits staff from engaging in sexual contact with

inmates.

19. Admit that the Bureau of Prisons Standards of Employee

Conduct prohibits staff from engaging in sexual intercourse

with inmates.

20. Admit that plaintiff Bobbie Bolton attended the Admission

and Orientation program at FCI Tallahassee in early November

2001.

21. Admit that during the Admission and Orientation program at

FCI Tallahassee, inmate Bobbie Bolton was advised of steps

to take to report improper actions toward her by staff.
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22. Admit that prior to filing her administrative tort claim,

plaintiff Bobbie Bolton never wrote to any Bureau of Prisons

staff member complaining that Officer Linton had sexual

intercourse with her.

23. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that

Officer Linton said “I want to fuck you” to her in July

2002.

24. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons staff member that in

July 2002 Officer Linton stated “you are a fine sister; a

girl like you can make a young man get in trouble”.

25. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that Officer

Linton would enter her cell and watch her while she was on

the toilet.

26. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that Officer

Linton entered the TV Room where she was cleaning on July

15, 2002, and asked her to draw the blinds so they could

have sex.

27. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that on July

15, 2002, Officer Linton stated “I want to fuck you.”
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28. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that on July

15, 2002, Officer Linton entered inmate Bolton’s cell and

threatened her.

29. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that on July

21, 2002, Officer Linton entered inmate Bolton’s cell and

stated that he was going to “fuck” her or make sure she went

to the Special Housing Unit.

30. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that on July

21, 2002, Officer Linton had sexual intercourse with her.

31. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never notified any Bureau of Prisons employee that on July

29, 2002, Officer Linton had sexual intercourse with her.

32. Admit that prior to August 7, 2002, plaintiff Bobbie Bolton

never provided the physical evidence of Officer Linton’s

sexual release to any Bureau of Prisons staff member.

33. Admit that once plaintiff Bobbie Bolton asked to speak to

the Special Investigative Agent that she saw him the same

day.

34. Admit that once plaintiff Bobbie Bolton told Special

Investigative Agent George Williams that she was raped, that

she was interviewed by the FBI on the very same day.
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35. Admit that plaintiff Bobbie Bolton did not provide Special

Investigative Agent George Williams, the FBI or the Officer

of Inspector General Agent the underwear she claims that

Officer Linton ejaculated on during the sexual encounter of

July 29, 2002. 

36. Admit that plaintiff Bobbie Bolton held physical evidence of

the purported rape in her possession for at least seven days

before she advised any Bureau of Prisons staff member of the

existence of the semen-stained nightgown.

37. Admit that SIA George Williams immediately placed plaintiff

Bobbie Bolton in the Special Housing Unit at FCI Tallahassee

upon her request for protection on August 7, 2002.

38. Admit that SIA George Williams took a statement from

plaintiff Bobbie Bolton concerning the alleged rape by

Officer Linton on the very day she notified him of the

situation.

39. Admit that on August 7, 2002, SIA George Williams asked for

the semen-stained nightgown that plaintiff Bobbie Bolton

retained.

40. Admit that on August 7, 2002, SIA George Williams obtained

the semen-stained nightgown that plaintiff Bobbie Bolton had

retained.

41. Admit that a piece of the semen-stained nightgown that

plaintiff Bobbie Bolton provided to SIA George Williams on
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August 7, 2002, was missing when Mr. Williams obtained the

nightgown. 

42. Admit that plaintiff Bobbie Bolton cut a piece out of the

semen-stained portion of the nightgown before she provided

it to SIA George Williams on August 7, 2002.

43. Admit that plaintiff Bobbie Bolton sent the cut piece from

the semen stain on the nightgown to an attorney prior to

reporting the alleged rape to Bureau of Prisons staff.

44. Admit that plaintiff Bobbie Bolton waited until she was

advised the cut piece from the nightgown was received by her

attorney prior to reporting the alleged rape to Bureau of

Prisons staff.

45. Admit that plaintiff was interviewed by FBI Agent Patrick

Sanford on August 7, 2002 concerning her allegations that

Officer Linton raped her.

46. Admit that on August 7, 2002, plaintiff told FBI Agent

Patrick Sanford that she allowed Officer Linton to have

sexual intercourse with her on July 21 and July 29, 2002

because she believed he could have her placed in

segregation, removed from the drug treatment program, or

could take away her transfer to a halfway house.

47. Admit that plaintiff Bobbie Bolton flirted with Officer

Linton.
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48. Admit that plaintiff Bobbie Bolton asked Officer Linton to

bring in a condom so they could have sexual intercourse.

49. Admit that plaintiff Bobbie Bolton never came into physical

contact with Officer Linton at FCI Tallahassee after August

6, 2002.

50. Admit that plaintiff Bobbie Bolton never had verbal

communication with Officer Linton at FCI Tallahassee after

August 6, 2002.

51. Admit that the sexual encounter between plaintiff Bobbie

Bolton and Officer Linton occurred in the Unit Officer’s

bathroom.

52. Admit that plaintiff’s cellmate, Natasha Johnson, stood

outside the office door as a lookout while plaintiff Bobbie

Bolton engaged in voluntary sexual intercourse with Officer

Linton.

53. Admit that plaintiff Bobbie Bolton arranged to have sexual

intercourse with Officer Linton in order to set up

litigation against the Bureau of Prisons.

54. Admit that plaintiff Bobbie Bolton’s halfway house placement

was delayed due to pending charges rather than any action by

Officer Linton.

55. Admit that on July 7, 1998, plaintiff Bobbie Bolton was

charged in the Southern District of Ohio with possession of

15 or more counterfeit devices in violation of 18 U.S.C.
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1029(a)(3), 371, and 2.

56. Admit that on December 4, 1998, venue for the Souther Ohio

charges was changed to the Western District of Missouri.

57. Admit that on December 4, 1998, plaintiff Bobbie Bolton was

charged in the Western District of Missouri with use of a

counterfeit credit card and possession of device making

equipment in violation of 18 U.S.C. 1029(a)(2), (a)(4),

(b)(1) and (c)(2).

58. Admit that on January 4, 1989, plaintiff Bobbie Bolton

pleaded guilty on the charges of possession of a counterfeit

credit card and possession of device making equipment.

59. Admit that plaintiff Bobbie Bolton used counterfeit credit

cards to defraud several merchants in Dayton, Ohio between

May 28 and 30, 1998.

60. Admit that plaintiff Bobbie Bolton used counterfeit credit

cards to make fraudulent purchases in four states in May of

1998.

61. Admit that plaintiff Bobbie Bolton used the alias Tracy

Callaway to rent a hotel in the Dayton metropolitan area on

May 28, 1998, and that she used a counterfeit credit card to

pay the bill.

62. Admit that on May 28, 1998, plaintiff Bobbie Bolton used the

alias Lashay Carrera to rent a U-Haul truck and storage

space and that she used a counterfeit credit card to pay for
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them.

63. Admit that on May 28, 1998, plaintiff Bobbie Bolton used a

counterfeit credit card in the name of Lashay Carrera-Teama

to purchase $1957.75 in goods from an electronics store.

64. Admit that on May 30, 1998, plaintiff Bobbie Bolton used a

counterfeit credit card in the name of Betty Boston to

purchase $1938.18 in goods from an electronics store.

65. Admit that plaintiff Bobbie Bolton knew the credit cards she

used to make purchases on May 28 and 30, 1998 were

fraudulent.

66. Admit that plaintiff Bobbie Bolton gave a false name to the

Dayton police when she was arrested on May 30, 1998.

67. Admit that plaintiff Bobbie Bolton was seen discarding a

wallet prior to her arrest on may 30, 1998.

68. Admit that the wallet plaintiff Bobbie Bolton discarded

prior to her arrest on May 30, 1998, contained four driver’s

licenses bearing her photograph with different names.

69. Admit that the wallet plaintiff Bobbie Bolton discarded

prior to her arrest on May 30, 1998, contained 20 altered

credit cards.

70. Admit that on July 8, 1998, plaintiff Bobbie Bolton was

arrested in Overland Park, Kansas, with an embossing

machine, 15 blank credit cards, five social security cards,

six blank California birth certificates and numerous pages
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with Visa and MasterCard numbers.

71. Admit that on February 21, 1989, plaintiff Bobbie Bolton

pled guilty to passing bad checks in Randolph County,

Missouri.

72. Admit that on March 1, 1989, plaintiff Bobbie Bolton pled

guilty to passing bad checks in Cooper County, Missouri.

73. Admit that on April 14, 1998, plaintiff Bobbie Bolton pled

guilty to passing bad checks in Boone County, Missouri.

74. Admit that on April 24, 1998, plaintiff Bobbie Bolton pled

guilty to passing bad checks and fraudulently stopping

payment on a check in Cole County, Missouri.

75. Admit that on December 19, 1995, plaintiff Bobbie Bolton

pled guilty to auto theft in Harris County, Texas.

76. Admit that on March 8, 1995, plaintiff Bobbie Bolton pled

guilty to receiving stolen property and forgery in Cole

County, Missouri.

77. Admit that on March 8, 1995, plaintiff Bobbie Bolton pled

guilty to stealing in Cole County, Missouri.

78. Admit that on October 14, 1997, plaintiff Bobbie Bolton pled

guilty to two counts of fraudulent use of a credit card in

Jackson County, Missouri.

79. Admit that on December 3, 1998, plaintiff Bobbie Bolton pled

guilty to theft in Johnson County, Kansas.

80. Admit that plaintiff Bobbie Bolton attended one semester of
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law school at Texas Southern University in 1991.

81. Admit that on October 27, 2003, plaintiff Bobbie Bolton pled

guilty to misuse of a social security number and fraud with

identification documents in Case Number 4:03CR139CEJ in the

United States District Court for the Eastern District of

Missouri.

82. Admit that on January 23, 2004, plaintiff Bobbie Bolton was

sentenced to serve 37 months incarceration in Case Number

4:03CR139CEJ in the United States District Court for the

Eastern District of Missouri. 

83. Admit that on October 2, 2002, plaintiff Bobbie Bolton was

placed in a community corrections center in St. Louis,

Missouri.

84. Admit that on December 8, 2002, plaintiff Bobbie Bolton

escaped from the community corrections center in St. Louis,

Missouri. 

85. Admit that Bureau of Prisons Psychology staff were available

to plaintiff Bobbie Bolton at FCI Tallahassee.

86. Admit that plaintiff Bobbie Bolton could have spoken to

Bureau of Prisons Psychology staff at any time between July

1 and August 7, 2002.

87. Admit that plaintiff Bobbie Bolton never advised a Bureau of

Prisons Psychology staff member at any time between July 1

and August 7, 2002 that Officer Linton was behaving in any
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inappropriate manner.

88. Admit that subsequent to August 7, 2002, plaintiff Bobbie

Bolton met with Bureau of Prisons Psychology staff on

several occasions.

89. Admit that a seven to 14 day delay in reporting an alleged

rape can result in loss of physical evidence to support the

allegation.

90. Admit that plaintiff Bobbie Bolton had access to medical

care at FCI Tallahassee.

91. Admit that plaintiff Bobbie Bolton was seen by medical staff

at FCI Tallahassee after August 7, 2002, when she first

reported the alleged rape.

92. Admit that medical staff at FCI Tallahassee conducted a

variety of medical tests for plaintiff after she reported

the alleged rape on August 7, 2002.

93. Admit that plaintiff Bobbie Bolton was given an Introduction

to Psychology Services handbook during Admission and

Orientation at FCI Tallahassee on November 1, 2001.
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94. Admit that plaintiff Bobbie Bolton was given a handbook

entitled “Sexual Abuse/Assault Intervention and Prevention,

An Overview for Offenders” during Admission and Orientation

at FCI Tallahassee in early November 2001.

Respectfully submitted,

GREGORY R. MILLER

United States Attorney

s/ Robert D. Stinson 

ROBERT D. STINSON

Assistant U.S. Attorney

Fla. Bar No. 319406

111 North Adams St., 4th Floor

Tallahassee, Florida 32301

850/942-8430

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing was filed electronically

on this 2nd day of April, 2004, and that James V. Cook, Attorney

for Plaintiff, is registered to be notified by the CM/ECF

electronic mail system.

s/ Robert D. Stinson 

Attorney