Free Opening Brief in Support - District Court of Delaware - Delaware

iO__.wwhOase 1:07-cv-00257-JJF - 11 Filed 06/07/2007 Page 1 014
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
O DELAWARE
DANIEL M. WOODS,
Plaintiff C.A.N.# gQu,77J‘ ésffw')
VS.
BOARD OF PAROLE,
STAN LY TAYLOR,
PATRICLA C“‘““’
REPHEAL WILLIAMS, T" I DE
THOMAS cAR0LL, [
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C“`“°Y °““GHT’ I
BRENDA CALLOWAY , LE
L. SULLIVAN, V. HAYES,P.RITER,
JANE DOE(ELW) AND CESCHERICH,
Defendants.
DECLARATION IN SUPPORT OF PLAINTIFFS MOTION FOR PARTIAL
, SUMMARY JUDGEMENT
DANIEL M. WOODS prose
1181 PADDOCK RD.
SMYRNA, DE. 19977

. Case 1:07-cv-00257-JJF Document 11 Filed 06/07/2007 Page 2 of 4
Pursuant to rule 56, Fed. R.Civ. P., plaintiff DANIEL M. WOODS requests
this Court to grant him summary judgment as to the liability of defendants
above for damages for the denial to the plaintiff of the due-process of law. The
reasons therefore are set forth in the plaintiffs affidavit and brief in support
of the motion.
I DANIEL M. WOODS, DECLARE UNDER PENALTY OF PERJURY:
I am the plaintiff in this above case; the complaint alleges that the plaintiff is being
punished without jurisdiction to do so and denied the plaintiff due-process of law.
Denied court ordered credits for time served, false imprisonment, placed in double
jeopardy enlarged the p1aintiff’s prison sentence in error that caused the plaintiffs
sentences to be increased. Parole dates, release dates, goodtime credits, affected
adding and the removals of goodtime credits, classifications, housing,
The removal of credits when plaintiff violated his parole (twice) before the errors
where fotmd. This error of calculations was and still is in affect for the last 25
years and has continued to harm the plaintiff These defendants have also
submitted false documents to the courts to try justifying the damages done to the
plaintiff and deny his court ordered credits which they do not have the authority to
do
I SUBMIT THIS DECLARATION IN SUPPORT OF MY MOTION FOR
PARTIAL SUMMARY JU DGEMENT

Case 1:07-cv-00257-JJF Document 11 Filed 06/07/2007 Page 3 of 4
I am an inmate at the Delaware Correctional Center, and I was falsely imprisoned
without due-process of law and the failure of all the above defendants to act caused
and continues to cause the plaintiff to suffer damages.
These defendants have failed to properly calculate the plaintiffs sentences that has
cause the plaintiffs sentences to be increased, this fact was and is admitted by the
defendants through an affidavit that they had eroded and increased the plaintiffs
sentences. These defendants have cause grave damages to the plaintiff and violated
his rights under the due-process and protect the plaintiffs liberty interests.
DATED: rb"] T ’ ° FULL SUBMI., _I
DANIEL M. WOODS prose U
D.C.C. 1181 PADDOCK RD.
SMYRNA , DE. 19977
S.B.I.# 164728

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