Free Motion to Appoint Receiver - District Court of Delaware - Delaware

Case 1:07-cv-00273-JJF

Document 19

Filed 11/02/2007

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Case No. 07­CV- 00273-*** ____________________________________________ Pamela Carvel, as Citizen, as Delaware Ancillary Administrator for Agnes Carvel Estate, as Member for Thomas and Agnes Carvel Foundation Plaintiffs v. William Griffin Marie Abplanalp Salvatore Molella Robert Davis and John/Jane Doe 1-20 Doe Corp. 1-20 Defendants ________________________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) AMENDED COMPLAINT

DEMAND FOR JURY TRIAL

PLAINTIFFS' MOTION TO APPOINT A RECEIVER Plaintiffs by Pamela Carvel hereby move this Court to appoint a Federal Receiver or the Delaware Attorney General on behalf of beneficiaries of charities pursuant to Rule 66 of the Federal Rules of Civil Procedure to marshal, conserve, protect, hold funds, operate and, with the approval of the Court, dispose of any assets, wherever those assets may be found in which Defendants or their agents alleged a legal, equitable or beneficial interest in the name of the "Thomas and Agnes Carvel Foundation". The grounds for this Motion and supporting arguments from first hand knowledge and law are in the accompanying Affidavit of Pamela Carvel opposing Defendants' Motion to Dismiss and supporting Plaintiffs' Motion to Appoint A Receiver. October 29, 2007

/s/ Pamela Carvel__________________
Pamela Carvel, appearing pro se for lack of funds 28 Old Brompton Road, Suite 158 London W7 3SS England, U.K. US tel/fax 1 954 524 1909

Case 1:07-cv-00273-JJF

Document 19-2

Filed 11/02/2007

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Case No. 07­CV- 00273-*** __________________________________________________ ) Pamela Carvel, as Citizen, ) as Delaware Ancillary Administrator ) for Agnes Carvel Estate, ) as Member for Thomas and Agnes Carvel Foundation ) Plaintiffs ) v. ) William Griffin ) Marie Abplanalp ) Salvatore Molella ) Robert Davis ) and ) John/Jane Doe 1-20 ) Doe Corp. 1-20 ) Defendants ) __________________________________________________ ) ORDER The Court, having considered Plaintiffs' Motion to Appoint a Receiver,m and good cause having been shown for the relief sought in the Motion, AMENDED COMPLAINT

DEMAND FOR JURY TRIAL

IT IS HEREBY ORDERED this _______ day of _____________, 2007 that the Motion is GRANTED and that a Receiver shall be Appointed.

________________________________ United States District Judge

Case 1:07-cv-00273-JJF

Document 19-3

Filed 11/02/2007

Page 1 of 1

CERTIFICATE OF SERVICE I, Pamela Carvel, appearing pro se, hereby certify that on October 31, 2007, a true and correct copy and disk of the foregoing document was sent by First Class U.S. Mail to be filed with the Clerk of the Court which will send notification that such filing is available for viewing and downloading to the following counsel of record, and also sent same by First Class U.S. Mail to: Richards, Layton & Finger, P.A. One Rodney Square, P.O. Box 551 Wilmington, DE 19801 (302) 651 7700

/s/ Pamela Carvel
________________________________________ Pamela Carvel, appearing pro se for lack of funds 28 Old Brompton Road, Suite 158 London W7 3SS England, U.K. US tel/fax 1 954 524 1909