Free Amended Complaint - District Court of Delaware - Delaware

Case 1 :06-cv—00008-GI\/|_S Document 25 Filed 07/17/2006 Page 1 of 4
IN THE UNITED- STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SANDRA J. WHITE ] ‘ ‘ ·
] A F I It E D
Plaintiff, ]
I JUL 1 7 ms
VS I .
, I ii i U · n__ i
DETECTIVE MARZEC, ] f .
TOWN OF DELMAR, ] ` s' · E
MARVIN MAILEY, AND ] RO Jcunmd i
CITY OF DOVER, AGENT ]
TOM JACOBS, AGENT ]
citrus Quaormo and ] bb- 8 C I0°¢J 5
DRUG ENFORCEMENT ]
AGENCY ]
I
Defendants, ] = _ - [
I · `AMENDED“COMPLAINT_— -
· ·‘·f‘ Now Comes the plaintiff, Sandra J. White, pro se, who so moves i
the Honorable Court, pursuant to Fed. Rule Civ. Pro. 15 and in support I
of the same the following is submitted:
(1). It is a common policy of towns [Town of Delmar] and cities
[City of Dover] to allow certain officers to work undercover with DEA.
but (a) these officers are still their employees (b) they still utilizes that
Town or City’s badge of authority and (c) while working DEA operations
they use the ‘badge of authority’ of that Town or City, to obtain warrants,
make arrests and file docmnents in Courts using that Town or City’s
Police Department as the Arresting Agency.
a. All this is done with ‘full’ knowledge , understanding and
authorization ofthe same by that Town [Town of Delmar] and City
[City of Dover] and they are whooly responsible for damages claimed
By plaintiff this is more than a ‘casual link’ in this matter.
in [ ` (2). Sandra White, has suffered greatly at the ‘hands’ of Det.
Marzec and his fellow officers, and their actions has violationed her
rights under 4th Amendment Illegal Search and Seizure as well
transgression upon 14th Amendment rights of Due Process and Equal
Protection ofthe Law.

Case 1:06-cv-00008-Gl\/IS Document 25 Filed 07/17/2006 Page 2 of 4
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Wlrite vs Marzec, et al., C.A. 06-009-KAJ {
a. She was handcuffed and gun pointed in her face, searched
and seized, because of Marzec’s ‘poor trainir1g’ and supervision and
Officer Marvin Mailey was the main culprit of this violation, because
He made initial contact with Ms White and created the abuse and the _
City of Dover, is responsible for his ‘poor training and supervision’ p
All that occurred on 08-21-05 could have been avoided. g
b. First and foremost Marzec and Officer Marvin Mailey and
their other fellow Officers should have never been Lincoln Delaware T
residence, because their search warrant was for a (a) single wide tan
and white mobile home (b) the warrant authorized searches and seizure ,
in Ellendale Delaware a.rrd © The Home in Lincoln, Delaware is a _
doublewide and Brown in color and such a home exist in Ellendale l
Delaware and many picture of it are in Court record. Pembaur v.
Cincinnati, 475 U.S. 469
c. The Town of Delmar, has even allowed it Police Chief V
Hal Saylor to participate in these type of actions. (a) this is a ‘show’ l
of "deliberate type of conduct" and signifies they are a "moving
force" in the actions of their subomated. Monell v. New York City
Dept., of Social Servs 436 U.S. 658 l
The failure to train and supervise Marzec and Officer Marvin ,
Mailey, falls directly upon the Town of Delmar and City of Dover as i
well as their fellow officer participating in the convert DEA action.
(a). what Marzec and Officer Marvin Mailey and their fellow officers J
did on 09-21-05, violated the civil rights of Ms White and shows l
the ‘deliberate indifference’ to substairr this "cause of action" against i
the Town of Delmar and City of Dover, because if ‘properly trairred’ .
Marzec and Officer Marvin Mailey, would-have known policemen K
just dorr’t search and seize at ag location that (a) the search warrant - J
doesn’t authorize (b) don’t search and seize a location that a judge I;
hasn’t authorized and (c).Know the difference from Lincoln and
Ellendale after a three month investigation and not lie about it. l
Canton v. Harris, 489 U.S. 378 l
Respec§fully,sulimitt§d r l
Sandra J. White i
9008 Green Top Rd p
Lincoln, DE. 19960
Dated July ll, 2006
J

Case 1:06-cv-00008-G|\/IS Document 25 Filed 07/17/2006 Page 3 of 4
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CERTIFICATE OF SERVICE
I,>J;()@ jg} 5. {Q il g‘ i g , verify service
Of the attached document, via U.S. Postal Service, on this ]j_th
Day of E yy L L B T 2006 with my signature I attest
The same. I
ggg gm ,1, wait
9008 Green Top Rd .
Lincoln, DE. 19960
Mr. Seth M. Beausang, Esq., Mr. Daniel A. Griffith, Esq.,
Asst. U.S. Attorney General 1220 Market St. Sth Floor
1007 Orange St. Suite 700 Wilmington, DE. 19801
Wilmington, DE. 19801

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