Free Motion to Compel - District Court of Delaware - Delaware

Case 1 :07-cv—00031 -G MS Document 56 Filed 10/19/2007 Page 1 of 3
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l IN THE UNITED STATES DISTRICT COURT I;
FOR THE DISTRICT OF DELAWARE
WHJLIAM JOSEPH VVEBB JR.,
PLAINTIFF, CIV. ACT. NO. : 07-31-GMS f
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V. i
FIRST CORRECTIONAL IVIEDICAL, JURY TRIAL REQUESTED i
ET. AL., q
DEFENDAN TS.
MOTION TO COl\/[PEL DELAWARE DEPT. OF CORRECTIONS TO RELEASE
PLAIN TIF F FROM THEIR CUSTODY.
Comes now, Plaintiff, William Joseph Webb Jr. requesting the Court to grant His MOTION TO
COMPEL DELAWARE DEPT. OF CORRECTIONS TO RELEASE PLAIN TIFF FROM THEIR j
CUSTODY to be heard before the Court at its earliest convenience and in support the following cause is q
shown: g ·
l. This motion is being filed in good faith.
2. Correctional Medical Services is a defendant in the matter, along with State Officials which r
causes a conflict of interest to Plaintiff where Plaintiff can no longer trust His health and
safety to the hands of people who have again violated Plaintiffs rights to adequate medical
care where His temperature has again risen to the high of l04.8°F, which is almost legally
dead.
3. On September 17, 2007, Plaintiff was sent to Kent General Hospital from Delaware
Correctional Center without adequate medical care which allowed His temperature to rise to
l04.8°F, the Plaintiff is most likely now suffering brain damage as a result in which testing
needs to be done immediately to see the damage and a treatment plan to minimize the
damage.
4. Plaintiff can no longer tmst the Delaware Department of Corrections with not even His
propeny in which without Due Process and reg =<.; . ` -— as i t been
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Di§RiiiT OF D LAWAR .
l U H Q7 S Cmfl {md

Case 1 :07-cv—00031 -G MS Document 56 Filed 10/19/2007 Page 2 of 3 I
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destroyed or allowed to be stolen, confidential and very important documents not only to this
litigation, but to Plaintiffs criminal case, 06-734—GMS, and college education.
5. Release of the Plaintiff would resolve all of the animosity of the conflict of interest to have a
Defendant in a civil litigation to keep continuous wrongdoing to the Plaintiff which could
prove dainty.
6. There is no other possible remedy available to Plaintiff where CMS is the medical provider
for all of Delaware’s prisons, and release of Plaintiff into society would pose no threat to
anyone, and Plaintiff would be able to get His own medical insurance and protect Himself
7. Plaintiff is now suffering emotional distress where if He can’t trust the Delaware Department
of Corrections with His health and safety He will have to protect Himself by killing all those
responsible for these actions. - ip
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RELIEF REQUESTED: The Honorable Court issue an order to compel the Delaware Department of I
Corrections to release Plaintiff from their custody.
Respec full Sub `tted
Dated: October 16, 2007 Z,Z;__/ ~‘
William Joseph Webb Jr.
#256056/ D/EF14B
1181 Paddock Road
g Smyrna, DE 19977
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Case 1:07-cv-00031-G|\/IS Document 56 Filed 10/19/2007 Page 3 of 3
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Certificate of Service I
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I, William J. Webb Jr. hereby certify that I have served a true and correct cop(ies) of 1
the attached Motion to Compel Dept. of Corr. to release Plaintiff from their custody Upon j
the following parties/persons: ` 1
To: Catherine Damavandi 1
820 North French Street
Sixth Floor
Wilmington, DE 19801 - 1
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To: Patrick G. Rock
913 Market Street :
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Ste. 800 1
Wilmington, DE 19801
To: First Correctional Medical i
205 W. Giaconda Way *
Ste. 115 l
Tucson, AZ 85704
To: Dr. Ali
1301 E. I2"` st.
Wilmington, DE 19809
BY PLACING SAME IN A SEALED ENVELOPE, and depositing same in the United States
Mail at the Delaware Correctional Center, Smyrna, DE 19977.
On this 16 day of October, 20Q
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William J. We Jr. #256056