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

Case 1:07-cv-00193-MPT

Document 29

Filed 12/06/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE C. H., Plaintiff, v. THE CAPE HENLOPEN SCHOOL DISTRICT, et al., Defendants. : : : : : C. A. No. 07-cv-00193-MPT : : : : :

PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Plaintiff C.H., by counsel and pursuant to Fed. R. Civ. P. 56, hereby moves this Court to enter summary judgment in favor of Plaintiff, finding that the Hearing Decision and Order issued by the Hearing Panel on January 6, 2007, was issued in error and contained erroneous conclusions of law and findings of fact; that there are no genuine issues of material fact; and that Plaintiff is entitled to judgment as a matter of law. The reasons for this motion will be set forth in a Memorandum of Points and Authorities to be filed on December 21, 2007, pursuant to LCvR 7.1.3.(c), as well as the Statement of Material Facts as to Which There Is No Genuine Issue. A proposed order will also be submitted therewith. Respectfully submitted, /s/ Bruce L. Huson Bruce L. Hudson, Esq., Delaware Bar No. 1003 800 N. King Street, Suite 302 Wilmington, DE 19801 (302) 656-9850 _/s/Wayne D. Steedman_ Wayne D. Steedman, Federal Bar No. 09474 Callegary & Steedman, P.A.

Case 1:07-cv-00193-MPT

Document 29

Filed 12/06/2007

Page 2 of 2

201 N. Charles Street, Suite 1402 Baltimore, Maryland 21201 410-576-7606

December 6, 2007 Date