Free Response to Motion - District Court of Delaware - Delaware

. Case 1 :06-cv-00018-JJF Document 62 Filed O9/O4/2007 Page 1 of 2
CLERK OF THE COURTS ` 06-018-IIF
UNITED STATES DISTRICT 08-27-07
844 N.KING STREET -
WILMINGTONDELAWARE . .
OPISITION TO DEFENSE
· ` SUMMARY JUDGEMENT
. _ THAT THE _
OFFICERS LEGATES AND WHEATLEY SHOULD BE DENIED QUALIFIED
IMMUNIT Y FOR THEY KNEW THAT WHAT THEY WERE DOING WAS
` EXCESSIVE BECAUSE THEY FAILED TO TELL T HE TRUTH IN THEIR
STATEMENTS IN AN ATTEMPT TO COVER UP THEIR EXCESSIVE FORCE `
AND ASSAULT ON HOWARD LASKEY ON JANUARY 3,2004. THAT THE
OFFICERS KNEW THE DIFFERENCE OF WHAT THEY WERE DOING AND _
ENTERED FALSE WITNESS TO COVER UP THEIR EXCESSIVE FORCE.
THAT THE DEFENSE
IS WITHHOLDING EVIDENCE AND DID DECIEVE THE PLANTIFF AS TO
INFORMATION REQUESTED BY THE PLAINTIFF. THAT THE ONLY RESULT
TO THE TRUTH OF THE PLAINTIF FS CLAIM CAN BE ACHIEVED AT TRLAL. ·
THAT THE
OFFICERS LEGATES AND WHEATLEY ATTEMPTED TO COVER UP THEIR
ACTIONS SHOWED THAT THEIR ACTIONSWERE NOT AN HONEST MISTAKE
AND THAT THEIR FALSE WITNESS SHOWS THAT THEY WHERE .
KNOWLEDGEABLE. TO THE WE.ASO}I.ABLENESS OF THE FORCE USED;
· THAT THE TOWN OF ·
MILLSBORO AND THE MILLSBORO POLICE ARE RESPONSIBLE FOR THE
. ACTIONS OF THEIR OFFICERS IN THE LINE OF THE OFFICERS DUTIES. -
CC.BRUCE HERRON VIA U.S. MAIL _ ' /!ECTFUL Y ,
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Case 1 :06-cv-OOO18-JJF Document 62 Filed Page 2 of 2
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