Free Motion for Summary Judgment - District Court of Delaware - Delaware

.. Case 1:07-cv—OO237-JJF Document 9 Filed 08/O1/2007 Page 1 of 2’ JQV
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE _
Agnes Carvel Estate, London, England )
by Pamela Carvel, Executrix, )
Plaintiif )
v. _ ) Case No. 07 CIV 000237-.UF
)
Carvel Corp. )
a Delaware corporation )
Defendant. l `
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT OR
TO AMEND COMPLAINT
Plaintiff Pamela Carvel, fiduciary to Agnes Carvel and her successors
- in interest, Delaware ancillary administrator for the Agnes Carvel Estate,
and Executrix for the period in question (through April 2007) hereby moves
the court for summary judgment or for leave to amend the Complaint.
As explained in more detail in the accompanying memorandum,
Pamela’s prima facie: evidence shows Agnes Carvel and her successors in
interests are due rents and others sums characterized as rent in the lease by
Carvel Corp., through its wholly owned subsidiary Franchise Stores Realty.
July 25, 2007 —· Respectfully submitted, ·
,~ w
Pamela Carvel, appearing pro se
28 Old Brompton Road, Suite 158
London SW7 3SS England
US tel/fax 1 954 524 1909

Case 1:07-cv—OO237-JJF Document 9 Filed 08/O1/2007 Page 2 of 2
CORRECTED FOR MOTION
CERTIFICATE OF SERVICE
I, Pamela Cazwel, appearing pro se, hereby certify that on July Q,
2007, a true and correct copy and disk of the foregoing document was sent
by overnight delivery to be iiled 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:
. Karen Keller
Young Conaway Stargatt & Taylor, LLP
The Brandywine Building
1000 West Street, 17m Floor
Wilmi¤st¤¤,DE19801 __ . ., ,,. . , in _. v_ s
302 571 6600 ii ,;__ B 1
Thomas Spillman _ AUG 2 3 Zggi] 5
Smith, Gambre1l& Russell, LLP — 2
Suite 3100 S u . s1’¥1iéi‘ `i_‘_ T
Pygmgnadg , 'll ml -__._ '§... .4” . ._ ij
1230 Peachtree Street N.E.
Atlanta, GA 30309-3.592
Additionally, I hereby certihz that on July §l_, 2007, copies of the
foregoing document were served via first class, postage pre-paid, to the
above parties. l g

‘ 4/ / /
Pamela Carvel, appearing pro se
28 Old_Bro1npton Road, Suite 15 8
London SW7 3SS England _
US tel/fax fwd 1 954 524 1909

Case 1:07-cv—OO237-JJF Document 9-2 Filed 08/O1/2007 Page 1 of 1
ibamcla (Samet
28 Old Brompton Road. Suite 158
1.¤¤d¤¤.sw7 3SS.Eng1aud.U.K. US TEL/FAX 1 954 524 1909
25 July 2007
United Stated District Court
District of Delaware
844 N. King Street
Wilmington, DE 19801
RE: 07-CV-00237-JJF
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT OR
LEAVE TO AMEND COMPLAINT
& AMENDED COMPLAINT, DEMAND FOR JURY TRIAL
Dear SlrIMadam,
+ { COP`}
Please file the enclosed 0riginal_Motlon and Affidavit in support of summary judgment or
motion for leave to amend the complaint and amended complaint. Also enclosed is a
CD containing the same papers.
lf there are any procedural points l have missed, please use the above US telephone
and fax forwarding number because mail forwarding takes a long time to reach England.
The above US number will forward to England at my expense.
Thank you for your valuable assistance.
Yo . _ ruly,
by Pamela Carvel EQ,
rs
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