Free Motion for Joinder - District Court of Delaware - Delaware

Case 1 :06-cv-00008-GI\/IS Document 21 Filed 06/23/2006 Page 1 of 3
.v— » ·i "i l
g it pin ras :srArEs DISTRICT counr
i iron ijtsrnicr or DELAIVIAB ·___ I Q ~ =
SANDRA]. WHITE ] I I I I ` `I ·`·1
] Civil Action No. 06-008-KAJ
Plaintiff, ]
I I
1 . F is @ -
DETECTIVE MARZEC, in ] .
his Official and individual ] _ JUN 2 3 mug [
capacity, AGENT TOM ] -
JACOBS, and AGENT - ` ] US mH»—mC...
- - COURT
CHRIS QUAGLINO. TOWN] I J unstmcr or daiiwnqs
of DELMAR, ]
I ‘ BJ Sranfw rf
PLAINTIFF’S MOTION OF PERMISSIVE JOINER
- OF OFFICER MARVIN MAILEY & CITY OF DOVER
NOW Comes the plaintiff] Sandra J. White, pro se, who so
moves the Honorable Court, pursuant to.E_ed Rule Civil Pro. 20(a)
with her_l\/lotion of`Permissive Joiner, in support ofthe same the
following is asserted; ·· V no . Z . . _ __
H [1]. The City of Dover is were Officer Marvin Mailey
Is employed as a police officer.
a. The City of Dover is responsible for his training,
supeivison and authorization of duties.
[2]. Officer Marvin Mailey, was present and participating - I
In activities that Ms White, has complained of on 09-21-2005.
a. Officer Mhrvin Mailey, was the Officer who first made
contact, with plaintiff Sandra J. White.
I , ` b. His approach was at gun point ri@t in her face as well
as he handcuffed her and patted her down.
c. There were two(2) other women at that residence at that
time and neither, were handcuffed or patted down and one Denise _ _
Hinton was right behind me. ‘
[3]. Upon his [Officer Mailey’s] first encounter with me
I explained to I don’t carry weapons or drugs and that I wasn’t
I

Case 1:06-cv-00008-G|\/IS Document 21 Filed 06/23/2006 Page 2 of 3
5
White vs Marzec, et at., C.A. No. 06-008-KAJ J
Well and had an Aneurysm and maj or surgery, very recently.
I had maj or surgery to repair the aneurysm on 12-26-04 and Q
skull replacement surgery on 05-16-05. . '
a. He jokingly responded “Oh your sick huh" and then
he handcuffed me and patted me down, _when no other female
suffered that fate.
·b. 1 suffered immediate effects [pain, aguish, mentally
and physically and a fluid problem in my head] which uttimately ]
led to hospitalization several month later. [04-24-06] .
The police as well as Officer Marvin Mailey, had no legal
Or lawful reason or purpose for being at the residence and my pain ‘
And suffering and violation of my constitutional rights against
illegal search and seizure should have never occurred on 09-21-05.
[4]. The City of Dover and Officer Marvin Mailey,,as a
matter of can and should be added as defendants, because (a) it ]
being asserted against them jointly, severally in regards to relief
sought by Sandra J. Vlfhite (b) all claims are arising out of one
transaction as well as one occurrence and (c) any question of law
and all fact are common to all defendants and their respective
liabilities are the same.
Dated __th day of June 2006 R spect l1y,subrnitted _
. . S. L>1'ltJ(g$\'
if Sandra J. White _
9008 Green Top Rd
Lincoln, DE. 19960
So Ordered this Ath of 2006, the City of Dover
And Officer Marvin Mailey, are now Defendants in this Civil Action
No. 06-008-KA].
U.S. District Court Judge Keneth A. Jordan
With my signature, I Sandra J. White, verify service of
Attached document upon Mr. Seth M. Beausang, Esq., Asst. U.S.
Attorney at 1007 Orange St. Suite 700, Wilmington, DE. 19801 &
Mr. Daniel A. Griffith,Esq., at 1220 Market St. Sth Floor, Wilmington,
DE. 19801, on this 2;/[th day of June 2006

Case 1:06-cv-00008-G|\/IS Document 21 Filed 06/23/2006 Page 3 0f 3
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