Free Motion for Reconsideration - District Court of Delaware - Delaware

Case 1 :05-cv-00877-JJF Document 36 Filed 06/08/2007 Page 1 of 3
HY TH UNITED STATES DISTRICT COURT Q
FGR TE DISTRICT- OF DELAWARE ·
Roland C. Anderson : .
vs. I Civil Action No. 05-377-JJF `-``` `" ` ‘’TT‘= ·=·-
General Motors Corp. _ - · A l Tnizdllll A T
. : mO__nzmg__:h =iUti-r't@ t
Motion for Rigjst for Counsel
I request forcounsel set forth in Tabran V. Grace, 6F .3d 147 (3d cir. 1993) enter
tile of civil rights act.
T`ne Third Circuit developed a list of criteria to aid district courts in weighing _
whether to request a lawyer. T
1. The P1ainti:Et’s ability to present his or her own case (my answer). I am not a
lawyer and know little of the law to represent myself for justice.
2. Court states Plaintiff has not met the threshold issue. He has not demonstrated I
T that his discrimination claim has some arguable merit in fact and law. .
Your Honor this is why I request a lawyer because 1 am not, but clearly DOL state
that this claim come under title -411 of the Civil Rights Act of 1964. DOL attached. It
is clear No. IUI overcome this hurdle (see DOL and their own investigation).
3. The difliculty of the particular legal issues, again I am not a lawyer and
T according to DOL investigation, it was discovering G.M. violated Title 7 and
mislead DOL — see attached document. lt is clear there are legal issues
(Require a lawyer). I
4. The degree to which factual investigation will be necessary and the ability of
the Plaintiff to pursue investigation. (I feel I meet this hurdle as well as stated
above). Your Honor in respect to this Court, I am not a lawyer to legal issues.
5. The Plaintiff is capacity to retain counsel on his or her own behalf A _
Your Honor I try and try to get a lawyer and can get verification from or try to plus
legal aid in which that do not do. This is why I requested counsel. .

Case 1:05-cv-00877-JJF Document 36 Filed 06/08/2007 Page 2 of 3
6. The extort to which a case is likely to turn on creditability, determination. n ‘ A
Your Honor clearly G.M. creditability is in question. I was never hired as a
temporary worker nor terminated. Please see admit from Dave Bull to this Court to show
I was an hourly worker. “ '
Id. At I5 55-57 additional consider with respect to a Title 411 case are the efforts I
taken by a Plaintiff to obtain Counsel Plaintiffs financial ability to retain counsel.
Clearly I reached this hurdle as well for counsel. See Hich v. ABI Assoeiate·r¤$“*‘**”*“77‘iF*
Inc., 5'/ZZ F.2d960, 969 (3d cir. 197 8), Coston v. Sears, Roebuck & Co, 5561* .2d 1305,
1309 (Sm Cir. 1977). .
Your Honorlon page 3 of your memorandum order you said based upon its
investigation the EEOC is unable to conclude that the information obtained establishes
» violation ofthe statutes DOL investigation is attached shows G.M. violated their statute,
copy attached. I I
You also said (I have some) legal system and ability to present his own case by
making several filing. But you also said, has not inet the threshold issue. Your Honor it
is clear I am not a lawyer and need a lawyer to help melwith other legal issues for my
rights. But Iwas still denied for counsel and feel that I met their requirements. for
counsel. I am not a lawyer. I
Thank you,
KJM/3 g,,,£7W
Roland C. Anderson .
113 Lloyd Street
· Wilmington, DE 19804 ( _
Cert. of Service: I
The Honorable Judge Faman p
(Michael Basinkell, Wilmington, DE
one of attorney for Defendant ·‘ ‘

Case 1 :05—cv$00377—JJF Document 36 Filed 06/08/2007 Page 3 of 3
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` Sr.¤¤·E on DELAWARE. DEPARTIWENT o1=·LABoa
. DIVISION OF INDUSTRIAL. AFFAIRS ·
· Division o1= Ixousuuiu. A1=1=A1as
4425 Noam Mpxmcar STREET
Wrummron, DE 19802 #4,,-} » — r· "
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" ° PRIVACY A CT STA TEMEN T
_ Dear Charging Party: ‘
n 1. Please be advised that the information you have provided comes under the provisions of rr
the Privacy Act of 1974, Public Law 93-579.
2. 7 The authority for requesting the personal information contained herein are provided in 42
U.S.C. 2000e(9), 29 U.S.C. 201, 29 U.S.C. 621; and 19 Del. C. § 712(c).
3. The principal purpose of obtaining this information is to complete the Charge of -- y
Discrimination which will be verified by the Charging Party and served upon the p
Respondent. In some instances, witnesses’ sworn statements may become relevant to ‘
determining the Charge of Discrimination.
4. These forms are used to initiate and investigate the Charge of Disciirninationunder the
‘ laws and to impeach or substantiate a witness’s testimony. .
. 5. Completion of the Verified Charge of Discrimination form is mandatory to initiate and
__ p _ M __ 4 A __, ,prgc•gs__a Ch,B1'gQ_,Q£D 0IIa·~-- 8£ld:l·tl011&lL111fOHH3ll`OI1_0f1`[l3?V€I’lHCE{IlOl1-C 9 "" C
fonn is optional. Failure to provide additional information has no effect on Department
of Labor’s ability to file and process the Charge of Discrimination.