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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DEFENDANT’S RULE 26(A)(1) DISCLOSURES

COMES NOW, the United States of America by and through the undersigned Assistant

United States Attorney, and hereby submits the following initial disclosures of discovery

information, in accordance with Rule 26(a)(1) of the Federal Rules of Civil Procedure. 

A. People with knowledge:

1. Jeffery Linton, 8415 W. Tennessee St., Tallahassee, FL 32304 -

information about his actions relevant to the complaint

2. Bobbie Bolton, Register No. 07304-031, Federal Transfer Center, 7410 S.

MacArthur Avenue, P.O. Box 898802, Oklahoma City, OK 73189-8802 -

information about her actions relevant to the complaint

3. George Williams, Special Investigative Agent, Federal Correctional

Institution, 501 Capital Circle, N.E., Tallahassee, FL 32301 - information

concerning his investigation into plaintiff’s allegations

4. Dr. B. Hernandez-Ricoff, Clinical Director, Federal Correctional

Institution, 501 Capital Circle, N.E., Tallahassee, FL 32301 - information

concerning the medical care plaintiff received subsequent to her complaints

to prison staff

5. Lonnie Davis, Special Agent, Office of the Inspector General, 3800
2

Inverrary Blvd., Suite 312, Ft. Lauderdale, FL 33319 - information

concerning his investigation into plaintiff’s allegations

6. Pat Sanford, Special Agent, Federal Bureau of Investigation, 227 North

Bronough Street, Suite 6300, Tallahassee, FL 32301 - information

concerning his investigation into plaintiff’s allegations.

7. Wynette Kirby-Brown, Drug Treatment Specialist, Federal Correctional

Institution, 501 Capital Circle, N.E., Tallahassee, FL 32301 - information

concerning plaintiff’s report of sexual abuse to prison staff.

8. Allen Hanley, Chief Psychologist, Federal Correctional Institution, 501

Capital Circle, N.E., Tallahassee, FL 32301 - information concerning

plaintiff’s mental health status, as well as information on the Sexual

Abuse Assault Intervention and Prevention Program at FCI Talladega.

B. Description of Documents

1. Plaintiff’s central file, located at her institution of confinement

2. Plaintiff’s medical file, located at her institution of confinement

3. Defendant Linton’s Personnel file, located at FCI Tallahassee

4. Defendant Linton’s training record, located at FCI Tallahassee

5. SIS file concerning alleged sexual abuse on July 21 and 29, 2002, located

at FCI Tallahassee

6. Investigative material in USA v. Linton, 4:03cr26WCS, located at the

Office of the Inspector General, Miami Field Office

7. FTCA administrative claim file for plaintiff’s claim, No. TRT-SER-2003-

00706 

8. Administrative grievances filed by plaintiff relevant to the issues raised in

the complaint.

The United States of America is disclosing the existence of the above information but

maintains that some of it is not discoverable. The United States of America preserves any and

all objections to its disclosures.
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C. Computation of Damages - None

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

March, 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