Free Response to Motion - District Court of Delaware - Delaware

Case 1:06-cv-00011-SLR

Document 18

Filed 01/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE LEONARD K. BAYLIS, v. STANLEY TAYLOR, et al., Defendants. Plaintiff, ) ) ) ) ) ) )

C. A. No. 06-11-SLR

STATE DEFENDANTS' RESPONSE TO PLAINTIFF'S MOTION FOR EMERGENCY INJUNCTIVE RELIEF Defendants Stanley Taylor and Thomas Carroll ("State Defendants") respond to Plaintiff Leonard Baylis' Motion for Emergency Injunctive Relief, [D.I. 3], and to this Court's Order of January 9, 2006, [D.I. 4], by adopting herein by reference Defendants Chris Malaney and Correctional Medical Services' Memorandum of Points and Authorities in Support of Opposition to Plaintiff's Motion for Emergency Injunctive Relief.1 [D.I. 18]. WHEREFORE, Defendants Stanley Taylor and Thomas Carroll respectfully request that this Court deny Plaintiff's Motion for Emergency Injunctive Relief and enter an Order in the form attached hereto. STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Eileen Kelly Deputy Attorney General Carvel State Building 820 N. French Street, 6th Floor Wilmington, Delaware 19801 (302) 577-8400 [email protected] Attorney for State Defendants

Dated: January 20, 2006
1

At this time, State Defendants do not adopt Chris Malaney and Correctional Medical Services' Motion to Dismiss the Complaint.

Case 1:06-cv-00011-SLR

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Filed 01/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE LEONARD K. BAYLIS, Plaintiff, v. STANLEY TAYLOR, et al., Defendants. ) ) ) ) ) ) ) ) ORDER IT IS SO ORDERED, this _______ day of _____________, _________, that Plaintiff Leonard Baylis' Motion for Emergency Injunctive Relief is hereby DENIED.

C. A. No. 06-11-SLR

___________________________________ United States District Judge

Case 1:06-cv-00011-SLR

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Filed 01/20/2006

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CERTIFICATE OF SERVICE I hereby certify that on January 20, 2006, I electronically filed State Defendants' Response to Plaintiff's Motion for Emergency Injunctive Relief with the Clerk of Court using CM/ECF. I hereby certify that on January 20, 2006, I have mailed by United States Postal Service, the document to the following non-registered party: Leonard Baylis.

/s/ Eileen Kelly Deputy Attorney General Department of Justice 820 N. French St., 6th Floor Wilmington, DE 19801 (302) 577-8400 [email protected]