Free Answer to Amended Complaint - District Court of Delaware - Delaware

Case 1:07-cv-00365-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE USHANGO OWENS, : : Plaintiff, : : v. : : GOVERNOR RUTH ANNE MINOR, : DELAWARE STATE EMPLOYEES, : OFFICER FOX, OFFICER KIRKLIN, : MAYOR JAMES BAKER, WILMINGTON: HOSPITAL EMERGENCY, : WILMINGTON POLICE DEPARTMENT, : and, GANDER HILL PRISON HRYCI, : : Defendants. :

C.A. No. 07-365 JJF

DEFENDANTS FOX, KIRLIN, DELEO, KURTEN, PUIT AND MORRISSEY'S ANSWER TO THE COMPLAINT (D.I. 2) I. Previous Lawsuits A. No allegations are set forth in this paragraph. As such, no response is required from Defendants. II. Exhaustion of Administrative Remedies A. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. B. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge

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and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. C(1-2) The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. Defendants 1. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. 2. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. 3. Admitted that Defendant Officers Robert Fox and MacKenzie Kirlin are employed by the Wilmington Police Department and that their business address is 300 Walnut Street, Wilmington, DE. Statement of Claim 1. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 2. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent

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that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 3. Relief 1. Denied. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE Plaintiff fails to state a claim upon which relief can be granted. SECOND AFFIRMATIVE DEFENSE The Court lacks jurisdiction. THIRD AFFIRMATIVE DEFENSE The actions and conduct of Defendants did not rise to the level of a Constitutional violation and, therefore, Plaintiff did not suffer any infringement of his constitutional rights. FOURTH AFFIRMATIVE DEFENSE The actions and conduct of Defendants were objectively reasonable under the circumstances which Defendants were aware, therefore, their actions did not violate Plaintiff's Constitutional rights. FIFTH AFFIRMATIVE DEFENSE The actions and conduct of Defendants did not violate any clearly established Constitutional or Federal statutory rights of which Defendants reasonably should have been aware, and they are therefore entitled to qualified immunity. Denied.

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SIXTH AFFIRMATIVE DEFENSE The actions and conduct of Defendants were undertaken in the good faith performance of their official duties, without wantonness or malice, and were therefore privileged and immune. 10 Del. C. §4010 et seq. SEVENTH AFFIRMATIVE DEFENSE Plaintiff's damages, if any, are limited to 10 Del. C. §4013 et seq. EIGHTH AFFIRMATIVE DEFENSE To the extent that Plaintiff may have been injured, Defendants were not the proximate cause of any such injuries. NINTH AFFIRMATIVE DEFENSE Plaintiff's injuries, if any, were proximately caused by his own wrongful, wanton, willful, reckless, and/or negligent acts. TENTH AFFIRMATIVE DEFENSE Plaintiff has failed to establish supervisory liability with regard to his claims against Defendant Morrisey. ELEVENTH AFFIRMATIVE DEFENSE Defendant Fox was not present at the time Plaintiff was arrested and taken into custody.

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WHEREFORE, Defendants respectfully request that this Court dismiss Plaintiff's Complaint with prejudice, assess costs and reasonable attorney's fees against Plaintiff, and order such other relief as this Court deems appropriate.

/s/ Rosamaria Tassone Rosamaria Tassone, Esquire (DE Bar I.D. #3546) First Assistant City Solicitor City of Wilmington Law Department Louis L. Redding City/County Building 800 N. French Street, 9th Floor Wilmington, DE 19801 (302) 576-2175 Attorney for Defendants Fox, Kirlin, DeLeo, Kurten, Puit, and Morrissey

Dated:

August 11, 2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE : : Plaintiff, : : v. : : GOVERNOR RUTH ANNE MINOR, : DELAWARE STATE EMPLOYEES, : OFFICER FOX, OFFICER KIRKLIN, : MAYOR JAMES BAKER, WILMINGTON: HOSPITAL EMERGENCY, : WILMINGTON POLICE DEPARTMENT, : and, GANDER HILL PRISON HRYCI, : : Defendants. : USHANGO OWENS,

C.A. No. 07-365 JJF

DEFENDANTS FOX, KIRLIN, DELEO, KURTEN, PUIT AND MORRISSEY'S ANSWER TO THE AMENDED COMPLAINT (D.I. 25) Preliminary Statement The allegations contained herein state a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. Jurisdiction 1. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 2. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 3. Admitted upon information and belief that Plaintiff Ushango Owens is currently

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incarcerated. Defendants are without sufficient knowledge and/or information to admit or deny the remaining allegations set forth in this paragraph of the Complaint. 4. Admitted that Defendant Officers Robert Fox, James DeLeo, Matthew Kurten, and MacKenzie Kirlin are employed by the Wilmington Police Department. Denied that they are employed at "New Castle County, Inc." 5. Denied that members of the Wilmington Police Department assaulted or used excessive force against Plaintiff. The remaining allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 6. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 7. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 8. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent

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that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 9. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 10. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 11. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 12. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. Misuse of Force 13. Admitted that when Plaintiff refused to obey the verbal commands of Defendant

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Kurten to stop and continued to actively resist the police by fleeing from them, Defendant Kurten deployed his departmentally issued taser to stop Plaintiff's flight. It is also admitted that the taser did not have an effect on Plaintiff as evidenced from the fact that Plaintiff continued to run from the officers. 14. Admitted that Defendant Kurten struck Plaintiff in his thigh area with his departmentally issued ASP when Plaintiff continued to resist arrest by running, ignored Defendant's verbal commands to stop and the taser did not work. 15. Denied.

Denial of Due Process 16. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. Claims for Relief 17. 18. 19. 20. Denied. Denied. Denied. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 21. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent

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that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 22. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 23. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. Relief Requested A- F. Denied. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE 24. Plaintiff fails to state a claim upon which relief can be granted. SECOND AFFIRMATIVE DEFENSE 25. The Court lacks jurisdiction. THIRD AFFIRMATIVE DEFENSE 26. The actions and conduct of Defendants did not rise to the level of a Constitutional

violation and, therefore, Plaintiff did not suffer any infringement of his constitutional rights.

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FOURTH AFFIRMATIVE DEFENSE 27. The actions and conduct of Defendants were objectively reasonable under the

circumstances which Defendants were aware, therefore, their actions did not violate Plaintiff's Constitutional rights. FIFTH AFFIRMATIVE DEFENSE 28. The actions and conduct of Defendants did not violate any clearly established

Constitutional or Federal statutory rights of which Defendants reasonably should have been aware, and they are therefore entitled to qualified immunity. SIXTH AFFIRMATIVE DEFENSE 29. The actions and conduct of Defendants were undertaken in the good faith

performance of their official duties, without wantonness or malice, and were therefore privileged and immune. 10 Del. C. §4010 et seq. SEVENTH AFFIRMATIVE DEFENSE 30. Plaintiff's damages, if any, are limited to 10 Del. C. §4013 et seq. EIGHTH AFFIRMATIVE DEFENSE 31. To the extent that Plaintiff may have been injured, Defendants were not the

proximate cause of any such injuries. NINTH AFFIRMATIVE DEFENSE 32. Plaintiff's injuries, if any, were proximately caused by his own wrongful, wanton,

willful, reckless, and/or negligent acts. TENTH AFFIRMATIVE DEFENSE 33. Plaintiff has failed to establish supervisory liability with regard to his claims against

Defendant Morrisey.

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ELEVENTH AFFIRMATIVE DEFENSE 34. custody. WHEREFORE, Defendants respectfully request that this Court dismiss Plaintiff's Complaint with prejudice, assess costs and reasonable attorney's fees against Plaintiff, and order such other relief as this Court deems appropriate. Defendant Fox was not present at the time Plaintiff was arrested and taken into

/s/ Rosamaria Tassone Rosamaria Tassone, Esquire (DE Bar I.D. #3546) First Assistant City Solicitor City of Wilmington Law Department Louis L. Redding City/County Building 800 N. French Street, 9th Floor Wilmington, DE 19801 (302) 576-2175 Attorney for Defendants Fox, Kirlin, DeLeo, Kurten, Puit, and Morrissey

Dated:

August 11, 2008

Case 1:07-cv-00365-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE : : Plaintiff, : : v. : : GOVERNOR RUTH ANNE MINOR, : DELAWARE STATE EMPLOYEES, : OFFICER FOX, OFFICER KIRKLIN, : MAYOR JAMES BAKER, WILMINGTON : HOSPITAL EMERGENCY, : WILMINGTON POLICE DEPARTMENT, : and, GANDER HILL PRISON HRYCI, : : Defendants. : USHANGO OWENS,

C.A. No. 07-365 JJF

DEFENDANTS FOX, KIRLIN, DELEO, KURTEN, PUIT AND MORRISSEY'S ANSWER TO THE AMENDED COMPLAINT (D.I. 27) Preliminary Statement The allegations contained herein state a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. Jurisdiction 1. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 2. The allegations contained herein states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 3. The allegations contained herein states a legal conclusion to which no response is

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necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 4. Admitted upon information and belief that Plaintiff Ushango Owens is currently incarcerated. Defendants are without sufficient knowledge and/or information to admit or deny the remaining allegations set forth in this paragraph of the Complaint. 5. Admitted that Defendant Officers Robert Fox, James DeLeo, Matthew Kurten, MacKenzie Kirlin, and Michael Morrissey are employed by the Wilmington Police Department. 6. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 7. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 8. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this

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paragraph of the Complaint. 9. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 10. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 11. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 12. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 13. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the

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extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 14. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 15. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, the allegations contained in this paragraph are denied. 16. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, the allegations contained in this paragraph are denied. 17. Facts 18. Denied. Denied.

Misuse of Force 19. 20. Denied. Admitted that Plaintiff was transported to the Wilmington Hospital Emergency Room by members of the Wilmington Police Department where he was seen by a

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physician. Denied that Plaintiff was assaulted. Defendants are without sufficient knowledge and/or information to admit or deny the remaining allegations set forth in this paragraph of the Complaint. Denial of Due Process 21. Denied that any Wilmington Police officers harassed Plaintiff. The remaining allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 22. Defendants are without sufficient knowledge and/or information to admit or deny the remaining allegations set forth in this paragraph of the Complaint. 23. Defendants are without sufficient knowledge and/or information to admit or deny the remaining allegations set forth in this paragraph of the Complaint. 24. 25. Denied. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 26. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. Further, this paragraph states a legal conclusion to which no response is necessary. To the

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extent that a response is required, the allegations contained in this paragraph are denied. 27. Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 28. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. Further, this paragraph states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 29. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. Further, this paragraph states a legal conclusion to which no response is necessary. To the extent that a response is required, the allegations contained in this paragraph are denied. 30. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. Denial of Medical Care 31. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient

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knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 32. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. Claims for Relief 33. 34. 35. 36. Denied. Denied. Denied. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 37. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 38. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the

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extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 39. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. 40. The allegations contained herein are directed toward a party other than Answering Defendants and no response is required from Answering Defendants. To the extent that a response is required, Answering Defendants are without sufficient knowledge and/or information to admit or deny the allegations set forth in this paragraph of the Complaint. Relief Requested A-F. Denied.

Alternate Version of Damage Demand D-E. Denied. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE 41. Plaintiff fails to state a claim upon which relief can be granted. SECOND AFFIRMATIVE DEFENSE 42. The Court lacks jurisdiction. THIRD AFFIRMATIVE DEFENSE

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43.

The actions and conduct of Defendants did not rise to the level of a Constitutional

violation and, therefore, Plaintiff did not suffer any infringement of his constitutional rights. FOURTH AFFIRMATIVE DEFENSE 44. The actions and conduct of Defendants were objectively reasonable under the

circumstances which Defendants were aware, therefore, their actions did not violate Plaintiff's Constitutional rights. FIFTH AFFIRMATIVE DEFENSE 45. The actions and conduct of Defendants did not violate any clearly established

Constitutional or Federal statutory rights of which Defendants reasonably should have been aware, and they are therefore entitled to qualified immunity. SIXTH AFFIRMATIVE DEFENSE 46. The actions and conduct of Defendants were undertaken in the good faith

performance of their official duties, without wantonness or malice, and were therefore privileged and immune. 10 Del. C. §4010 et seq. SEVENTH AFFIRMATIVE DEFENSE 47. Plaintiff's damages, if any, are limited to 10 Del. C. §4013 et seq. EIGHTH AFFIRMATIVE DEFENSE 48. To the extent that Plaintiff may have been injured, Defendants were not the

proximate cause of any such injuries. NINTH AFFIRMATIVE DEFENSE 49. Plaintiff's injuries, if any, were proximately caused by his own wrongful, wanton,

willful, reckless, and/or negligent acts. TENTH AFFIRMATIVE DEFENSE

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50.

Plaintiff has failed to establish supervisory liability with regard to his claims against Defendant Morrisey. ELEVENTH AFFIRMATIVE DEFENSE

51.

Defendant Fox was not present at the time Plaintiff was arrested and taken into custody.

WHEREFORE, Defendants respectfully request that this Court dismiss Plaintiff's Complaint with prejudice, assess costs and reasonable attorney's fees against Plaintiff, and order such other relief as this Court deems appropriate.

/s/ Rosamaria Tassone Rosamaria Tassone, Esquire (DE Bar I.D. #3546) First Assistant City Solicitor City of Wilmington Law Department Louis L. Redding City/County Building 800 N. French Street, 9th Floor Wilmington, DE 19801 (302) 576-2175 Attorney for Defendants Fox, Kirlin, DeLeo, Kurten, Puit, and Morrissey

Dated:

August 11, 2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE USHANGO OWENS, : : Plaintiff, : : v. : : GOVERNOR RUTH ANNE MINOR, : DELAWARE STATE EMPLOYEES, : OFFICER FOX, OFFICER KIRKLIN, : MAYOR JAMES BAKER, WILMINGTON : HOSPITAL EMERGENCY, : WILMINGTON POLICE DEPARTMENT, : and, GANDER HILL PRISON HRYCI, : : Defendants. :

C.A. No. 07-365 JJF

CERTIFICATE OF SERVICE I, Rosamaria Tassone, Esquire, hereby certify that on this 11th day of August, 2008, I filed the Defendants Fox, Kirlin, Deleo, Kurten, Puit and Morrissey's Answer to the Amended Complaint (D.I. 27), Defendants Fox, Kirlin, Deleo, Kurten, Puit and Morrissey's Answer to the Amended Complaint (D.I 25) and Defendants Fox, Kirlin, Deleo, Kurten, Puit and Morrissey's Answer to the Amended Complaint (D.I 2) with the Clerk of Court using CM/ECF which will send notification of such filing(s) and that this document is available for viewing and downloading from CM/ECF. A copy of this document was also served by U.S. Mail, postage pre-paid to the following individual: Ushango Owens (SBI #240623) Howard R. Young Correctional Institution P.O. Box 9561 Wilmington, DE 19809 /s/ Rosamaria Tassone Rosamaria Tassone, Esquire (DE Bar I.D. #3546) First Assistant City Solicitor City of Wilmington Law Department Louis L. Redding City/County Building 800 N. French Street, 9th Floor Wilmington, DE 19801