Free Joinder - District Court of Delaware - Delaware

Case 1:07-cv-00239-JJF

Document 101

Filed 07/30/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE RICHARD E. CLARK, JR., ) ) Plaintiff, ) ) v. ) ) WARDEN RAPHAEL WILLIAMS, et al., ) ) Defendants. )

Civil Action No. 07-239-JJF Jury Trial Requested

STATE DEFENDANTS' JOINDER IN DEFENDANT DR. BINNION'S OPPOSITION TO PLAINTIFF'S RENEWED MOTION FOR APPOINTMENT OF COUNSEL [RE: D.I. 94, 96] COMES NOW, State Defendants Raphael Williams, Patrick Sheets and Jim Welch (the "State Defendants"), by and through the undersigned counsel, and hereby join in Defendant Dr. Binnion's Opposition to Plaintiff's Renewed Motion for Appointment of Counsel (D.I. 96) and incorporate herein by reference the arguments made therein. In light of the fact that Clark has failed to satisfy the Tabron factors, State Defendants contend that Clark's renewed request for counsel should be denied. WHEREFORE, State Defendants respectfully request that this Honorable Court deny Plaintiff's Renewed Motion for Appointment of Counsel (D.I. 94). STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 Attorney for the State Defendants Dated: July 30, 2008

Case 1:07-cv-00239-JJF

Document 101

Filed 07/30/2008

Page 2 of 2

CERTIFICATE OF SERVICE
I, Erika Y. Tross, Esq., hereby certify that on July 30, 2008, I caused a true and correct copy of the attached State Defendants' Joinder in Defendant Dr. Binnion's Opposition to Plaintiff's Renewed Motion for Appointment of Counsel [Re: D.I. 94, 96] to be served on the following individuals in the form and manner indicated: Via First Class Mail Inmate Richard E. Clark Jr. SBI # 477726 Howard R. Young Correctional Institution P.O. Box 9279 Wilmington, DE 19809 Via Electronic Delivery James E. Drnec, Esquire Balick & Balick 711 King St. Wilmington, DE 19801 /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General Delaware Department of Justice Carvel State Office Building 820 N. French Street, 6th Floor Wilmington, DE 19801 302-577-8400