Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1 :06-cv—00008-GIVIS Document 20 Filed 06/21 /2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SANDRA J. WHITE ]
I
Plaintiff, ] C.A. N0. 06-OOQ—KAJ
vs ] »-·--······-""""`f`[_' `__
1 I F I»._..-...;;a.¢.2.....§
DETECTIVE MARZEC, in ] E
His official and individual ] \ '
Capacity, AGENT TOM ] .. ` ZH
JACOBS, AGENT CHRIS ] Us Vt _ " Q "
QUAGUNO, and TOWN I mégrg _ _` __ ‘ . E L-$52.
of DELMAR, ] if
/
.- _ ..-il-.(_ S-
MOTION TO AMEND PLEADING TO ADD TOWN OF 5 ( d I
DELMAR AS A DEFENDANT
NOW Comes the plaintiff, Sandra J. \lVhite, pro se, who so
Moves the Honorable Court, pursuant to Fed. Rule Civ. Pro. l5(3)
(2)(A) & (B) Amendment of Pleading to add Town of Delmar as
a Defendant and in support of the same the following is asserted:
[l ]. Detective Marzec, is an officer and employee ofthe
Town of Delmar’s Police Department.
[2]. The injuries the plaintiff complains of are as a result
of this employee, and his not being properly trained, supervised
and the Town of Delmar’s authorization of his actions are a direct
causaction of these injuries.
[3]. Compliance with Fed. Civ. Pro. l5(3)(A) has already
occurred, because the Town of Delmar, has already bee_n served
this action via United States Marshall service on {2* wg
and are well aware of action and should have known they are a
party to this action.
In all fairness the Town of_Delmar isjust as liable as as
responsible as all named defendants as well as they are a party
to injuries suffered by plaintiff, because oftheir employee
Detective Marzec, who sought (a) warrants and (b) search warrants in
the name of the Town of Delmar, that iniated the actions that
led to my injuries and violations of my constitutional rights.

Case 1:06-cv—00008-G|\/IS Document 20 Filed 06/21/2006 Page 2 of 3
White vs Marzec, et al.,
f` _
i\)/I J-` ` _:)_ \`ti_·y__
Sandra J. White
9008 Green Top Rd
Lincoln, DE. 19960
1,*-. "jg M_`1;"i-i1Cl \· 1.. '\`L=.JiL , with my signature, verify sewice
of attached document, upon Mr. Seth M. Beausang, Esq., a U.S.
Attorney General, at 1007 Orange St. Suite 700, Wilmington, DE.
19801 and Mr. Daniel A. Griffith, at 1220 Market St. 5"` Floor,
Wilmington, DE. 19801, on this _th day ofJune 2006, via U.S.
Postal system.
So Ordered, this _th day of 2006, the Town of
Delmar, is a named Defendant, in Civil Action No. 06-009-KAJ
and must meet all responsibilities
U.S. District Court Judge

Case1:06-cv—00008-GIVIS Document 20 Filed 06/21/2006 Page30f3
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