Sexual Abuse Request for Production of Documents

Plaintiff’s First Request for Production of Documents

To: State of Maryland, Department of Juvenile Services, Defendant
From: Plaintiff, by and through undersigned counsel, Miller & Zois, LLC
Re: Sexual Abuse of LVN, Victor Cullen Center, Docket No. [Insert Case Number]

Pursuant to Maryland Rule 2-422, Plaintiff requests that Defendant produce the following documents within thirty (30) days of service at the offices of Miller & Zois, LLC, located at 1 South St, Suite 2450, Baltimore, Maryland 21202.

Unless otherwise stated, the relevant time period for these requests is from January 1, 2010, through the present.

Definitions

• “You” or “Your” means the State of Maryland, Department of Juvenile Services, and all agents, employees, officers, contractors, and representatives acting on its behalf.
• “Victor Cullen Center” refers to the juvenile detention facility located in Sabillasville, Maryland, operated by the Department of Juvenile Services.
• “Sexual abuse” includes any incident of sexual misconduct, sexual assault, or other inappropriate sexual conduct by employees, contractors, or other youth.
• “Document(s)” is defined broadly to include paper records, digital files, emails, texts, reports, complaints, policies, training materials, video footage, and electronically stored information (ESI).

Requests for Production

1. All incident reports, investigative files, and internal communications relating to allegations of sexual abuse, sexual misconduct, or assault at Victor Cullen Center involving youth in custody from January 1, 2010, to present.
2. All documents concerning any complaints, grievances, or hotline reports made by residents or staff at Victor Cullen Center relating to sexual abuse or inappropriate conduct by staff or other youth.
3. Personnel files, training records, and disciplinary records for all employees, contractors, or volunteers identified as having worked at Victor Cullen Center during Plaintiff’s period of incarceration.
4. All security footage, video surveillance, or digital recordings from Victor Cullen Center related to the dates of Plaintiff’s allegations or any incident involving Plaintiff identified in the Complaint.
5. All written policies, procedures, or protocols in place during the relevant time period concerning the prevention, reporting, and investigation of sexual abuse, staff misconduct, or youth-on-youth assault.
6. All communications between the Department of Juvenile Services and law enforcement, including the Maryland State Police, regarding sexual abuse allegations at Victor Cullen Center since 2010.
7. All documents submitted to or received from the Department of Justice, Office of Juvenile Justice and Delinquency Prevention (OJJDP), or the Prison Rape Elimination Act (PREA) auditors relating to Victor Cullen Center.
8. All PREA audits, reports, corrective action plans, and compliance reviews for Victor Cullen Center conducted between 2010 and the present.
9. Any and all prior civil complaints, lawsuits, or notices of claim involving allegations of sexual abuse or misconduct at Victor Cullen Center, regardless of whether they were resolved by settlement, dismissal, or trial.
10. All insurance policies, claims files, reservation of rights letters, or other documentation concerning insurance coverage or indemnity relating to claims of sexual abuse at Victor Cullen Center during the relevant period.
11. All shift rosters, duty assignments, and post logs for Victor Cullen Center staff working in Unit B and Unit D between January 1, 2018, and December 31, 2021, including but not limited to guards Christopher L. Hensley and Marcus Tate.
12. All internal memoranda, email communications, or meeting minutes involving Victor Cullen Center Warden Thomas L. Bristow or Deputy Superintendent Angela McKinnon concerning staff sexual misconduct or abuse-related complaints from 2015 to the present.
13. All records of investigations conducted by the Department of Juvenile Services’ Office of the Inspector General or internal affairs division into the conduct of Officer Kevin P. Styles, including any findings of excessive force, inappropriate behavior, or abuse of authority involving youth.
14. Any and all documents reflecting staff turnover, including hiring, resignation, termination, or reassignment of staff accused of inappropriate behavior with detainees, including any reassignment of staff to administrative duties pending investigation.
15. All logs or reports reflecting use of solitary confinement, room restriction, or lockdown status for Plaintiff during the period of alleged abuse, and the stated justification for such disciplinary actions.
16. All records relating to PREA training completion, sign-in sheets, training materials, and competency testing results for all Victor Cullen Center staff from 2010 to the present.
17. All complaints, incident reports, or emails referencing inappropriate conduct in the facility’s intake area, including alleged improper searches or pat-downs, particularly during Plaintiff’s admission or reentry periods.
18. All rosters, incident logs, and disciplinary reports concerning dormitory 3A from March through August 2019, including any allegations of staff turning off cameras, covering cameras, or failing to conduct required 15-minute rounds.
19. All records or communications regarding staff use of personal phones, unmonitored communication devices, or any unauthorized recording equipment within youth housing areas at Victor Cullen Center from 2016 to present.
20. All documents regarding the suspension, reassignment, investigation, or resignation of Victor Cullen Center guard Rachel D. Boone, including any internal complaints, performance reviews, or staff-to-staff reports concerning her behavior toward residents.
21. All incident reports and related documentation involving the use of force on juveniles by Officer Darren P. Lovett, particularly in connection with physical restraints, chemical agents, or prone holds, from 2017 to present.
22. All disciplinary hearing transcripts, summaries, or adjudication records for Victor Cullen Center residents accused of “false reporting” of sexual abuse, misconduct, or staff impropriety from 2010 to present.
23. All maintenance logs, work orders, or reports documenting malfunctioning or disabled surveillance cameras in housing units, showers, or staff-controlled areas during the Plaintiff’s incarceration.
24. All correspondence or communications between Victor Cullen Center administrators and the Maryland Attorney General’s Office regarding sexual abuse prevention or institutional liability.
25. All email communications or staff meeting notes referencing concerns about chronic understaffing, forced overtime, or lack of supervision in the youth housing units from 2015 through present.
26. Any and all written or electronic complaints submitted by Plaintiff during or after his/her time in custody at Victor Cullen Center, including sick call requests, PREA hotline submissions, or “kite” forms.
27. All documentation identifying security staff who were scheduled but failed to complete rounds or required bed checks in Plaintiff’s unit on dates related to the allegations in the Complaint.
28. All records identifying any third-party contractors or service providers (e.g., Aramark, Allied Universal, or Corizon Health) employed at Victor Cullen Center during the relevant period and any abuse-related complaints tied to those individuals.
29. All contracts, MOUs, or service agreements between the Department of Juvenile Services and outside investigators, monitors, or consultants tasked with reviewing conditions or allegations at Victor Cullen Center.
30. All suicide watch logs, special observation forms, or mental health referral records for Plaintiff or for any resident alleging sexual abuse during overlapping periods of Plaintiff’s incarceration.

 

Note: If you object to any request, please state the specific grounds for the objection and respond to the portion of the request to which you do not object.

Respectfully submitted,

MILLER & ZOIS, LLC
1 South Street, Suite 2450
Baltimore, MD 21202
Attorneys for Plaintiff