Free Response to Motion - District Court of Delaware - Delaware

Case 1:07-cv-00228-GMS

Document 12

Filed 10/01/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

JEFFREY D. HILL, Plaintiff, v. NEW CASTLE COUNTY POLICE DEPARTMENT, a division of New Castle County; and NEW CASTLE COUNTY, a municipal corporation, Defendants

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C.A. No. 07-228 (GMS) JURY TRIAL DEMANDED

DEFENDANTS' RESPONSE TO PLAINTIFF'S MOTION TO AMEND COMPLAINT

On or about September 21, 2007, Plaintiff Jeffrey D. Hill ("Plaintiff") filed a Motion for Leave of Court to Amend the Complaint ("Motion") that was filed on or about April 30, 2007 in the above-captioned matter. In his Motion, Plaintiff seeks to add Sgt. Andrea Hyden ("Hyden"), Capt. Mark Hitch ("Hitch") and Capt. Quinton Watson ("Watson") as defendants. These persons are named in their individual and official capacities for alleged discriminatory and retaliatory actions taken against Plaintiff. Department as a defendant. Defendants have no objection to the instant Motion, as the parties have agreed that Defendants will retain the right to assert any and all defenses that are or may become available to them during the course of this action, including but not limited to defenses pertaining to the proposed amendments relative to Hyden, Hitch and Watson. Plaintiff also seeks to remove New Castle County Police

Case 1:07-cv-00228-GMS

Document 12

Filed 10/01/2007

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Respectfully submitted, /s/ Megan Sanfrancesco Megan Sanfrancesco, First Assistant County Attorney (#3801) New Castle County Law Department 87 Reads Way New Castle, DE 19720 (302) 395-5130 Attorney for Defendants Date: October 1, 2007

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