Free Response to Motion - District Court of Delaware - Delaware

Case 1:07—cv—00377-JJF Document 19 Filed 06/03/2008 Page T-{of 4
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WILLIAM BOYD, >
Allstaff, Inc., >
B and R, Inc., >
William Boyd DBA Allstaff, Inc., >
William Boyd DBA B and R, Inc., >
Plaintiff >
>
VS. >
>
> Civ. No. 07-377-JJF
>
TEMPAY, Inc., >
>
Defendant >
>
>
Response to Defendants Motion to Deny the Amended Comglaint
Plaintiff
William Boyd
Allstaff, Inc.
B and R, Inc.
William Boyd DBA Allstaff, Inc.
William Boyd DBA B and R, Inc.
602 Tamara Circle
Newark, DE l97ll
(302) 368-9049
(302) 250-7484
Defendant
Tempay
20600 Chagrin Blvd, Ste 503
Cleveland, OH 44122
Date: gg hg
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Case 1 :07—cv—00377-JJF Document 19 Filed 06/03/2008 Page 2 of 4
RESPONSE TO DEFENDAN TS MOTION TO DISMISS AMENDED
COMPLAINT
INTRODUCTION
In my amended complaint; I was adding Allstafi Inc., B and R, Inc. and William Boyd
Doing Business As (DBA) Allstaff and B and R to be additional plaintiffs. I am asking
the court to recognize/accept this and the previous request to add theses (Allstaff, Inc., B
and R, Inc. and William Boyd Doing Business As (DBA) Allstaff and B and R) in being
plaintiffs.
The actions of Tempay, John Boyd, Krista Garrettson, Wilmington Trust and Insurance
and Financial Services has an adverse affect on the temporary market horizontal market
(as described inthe plaintiffs Amended Complaint and other motions). It has eliminated
Allstaff and B and R. They (Tempay, John Boyd, Krista Garrettson, Wilmington Trust
and Insurance and Financial Services) have also eliminated a temporary employment
agency Marquis Services, Inc. from ever competing (2007). Besides these three
companies, there are many others that have been eliminated. Tempay, John Boyd, Krista
Garrettson, Wilmington Trust and Insurance and Financial Services all benefited and still
are benefiting from their illegal monopoly while these companies (Allstaff, B and R, and
Marquis Services) and more are stunted and handicapped if not out of business.
There is a conspiracy with Tempay, John Boyd, Krista Garrettson, Wilmington Trust and
Insurance and Financial Services to illegally monopolize this temporary employment
horizontal market:
"Tempay, John Boyd, Krista Garrettson, Wilmington Trust, Robin Boyd,
Insurance and Financial Services, Stratus Services and Harry Morris have
monopolized, attempt to monopolized and conspired to monopolize the temporary
employment clients for construction and industrial workers and the financing
needed among several states." (Plaintiffs Amended Complaint pg. 5 Sherman
Act Section II paragraph 1)
They committed criminal offenses (bank fraud, forgery, embezzlement, identity theft,
extortion, and stealing (theft) being willfully committed) that prove the conspiracy. I
have contracts, emails, cancelled check, bank statements, illegal forged documents,
illegal use of business, documentation of telephone calls, witnesses, and I have been in
and heard conversations that all support the conspiracy (monopoly). These actions have
been going on predominately (but not limited to) from 2006 through 2003.
SUMMARY
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Case 1 :07—cv—00377-JJF Document 19 Filed 06/03/2008 Page 3 of 4
I would ask the courts to accept my addition to plaintiff on my amended complaint and
this response of:
Allstaff, Inc.
B and R, Inc.
William Boyd DBA Allstaff, Inc.
William Boyd DBA B and R, Inc.
William Boyd
(The entire list of above to be added to the plaintiffs)
(A11 plaintiffs have the same address as William Boyd)
I am asking for Tempay to repay all the monies and damages caused to each in every
plaintiff.
I appreciate the courts allowing me, Allstaff and B and R the opportunities to exercise my
rights (Allstaffs and B and R’s rights) as an American to pursue justice. I know I am
bringing up a lot of criminal offenses but there is a bigger picture of why the criminal
offenses were committed by Tempay, John Boyd, Krista Garrettson, Wilmington Trust
and Insurance and Financial Services. They were all part of the conspiracy and the
agreement to conspirer (grow and use) an illegal monopoly. As it has been brought up
numerous times of how an Anti-Trust case is expensive; I feel that it is imposed for the
courts to sway to not let me pursue justice. However, keep in mind how arrogant this
group is because they are trying to hide behind the threat that it would be expensive for
the courts. This says to me that they are saying it is okay to do illegal acts if it cost
money to bring them to justice.
I thank the courts for their time and consideration.
Sincerely,
@%%
William Boyd
Date: 06/03/08
CC:
Defendants Council
Katharine L. Mayer
Renaissance Centre
405 N. King Street, 8th Floor
Wilmington, DE 19801
(302) 984-6300
(302) 984-6399 (fax)
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Case 1 :07—cv—00377-JJF Document 19 Filed 06/03/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, William Boyd, hereby certify that on June 03, 2008, I delivered
and served a true and correct copy of Petitioner’s "Response to
Defendants Motion to Deny the Amended Complaint" to the Clerk
of Court of the USDC of Delaware for civil action number 07-377.
I further certify that I served a true and correct copy of the
foregoing document on the Defendant Tempay’s (Tempay, Inc.)
Council Katharine L. Mayer in the manner of priority mail.
Thank you,
William X
602 Tamara Circle
Newark, DE 19711
(302) 368-9049
Defendant’s Council info:
Katharine L. Mayer
Renaissance Centre
405 N. King Street, 8th Floor
Wilmington, DE 19801
(302) 984-6300
(302) 984-6399 (fax)