Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1 :06-cv—00009-GIVIS Document 19 Filed 06/21 /2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TAWANDA WEATHERSPOON ]
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Plaintiff ] C.A. No. 06-009-KAJ
v. ] " " I - U Tl
DETECTIVE MARZEC, in his ] ij...;;;._;;...w- ,
Official and individual capacity ] ( _ lg i
AGENT TOM JACOBS, and ] E _ _ -
AGENT CHRIS QUAGLINO, ] l
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Defendants, ] ¤lstn1c:1·=>:¤ oaatvaae [
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MEMoRANDUM RESPONSE or §{iQY\
NOW Comes the plaintiif Tawanda Weatherspoon, pro se who so moves the `
honorable
Court, with the following responses, and they go as follows;
(I). I do live and reside in the home that was illegally searched and seized,
on 09-21-05, by the named defendants.
(a). I have lived there for a substantial period of time and do have man
reasonable expectancy of privacy at the same property.
(2). The named Defendants, did enter the premises by force, with their
guns drawn, and didn’t ask permission to enter neither was given permission.
(a). The search warrant was for Trailer in Ellendale, labeled the Sales/
Packaging Trailer, and it fit the description of the place described in the Warrant
Totally in (a) color (b) design and (c) location which was Ellendale Delaware.
(3). The actions of defendants was malicious intented without care for
plaintiff medical condition or rights of plaintiff and should have never happen
to begin with.
(a). The defendant didn’t act in good-faith nor as well trained and
supervised policemen.
(4). My home is Lincoln Delaware isn’t trailer, but a double wide, (a)
it isn’t tan/beige with white trim and it is miles from Ellendale.

Case 1 :06-cv—00009-GIVIS Document 19 Filed 06/21/2006 Page 2 of 2
(5). A computer check for my address would have reviewed, on 09-21 -05
that my address was 9008 Green Top Road Lincoln, DE. 19960 [Enclosed is
a photocopy of my driver’s license]
,\B,especth111y,submitted _ _
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CERTTIFICATYE OF SERVICE
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I, 1 W C 1 C ~r · k Q M 6 V 5 :9, verify service of attached document
Upon all parties listed below, and do the 'same with my signature, on tlns Jéth
Day of May, 2006, via U>S> Postal Service system.
Respectfully,submitted l
L.-.( _; [ QI [,9Cc' i I
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Mr. Seth M. Beausang Mr. Daniel A. Griffith
Assistant U>S> Attorney 1220 Market St. 5"` Floor
1007 Orange St. Suite 700 Wilmington, DE. 19801
Wilmington, DE. 19801
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