Free MEMORANDUM in Support - District Court of Delaware - Delaware

. Case 1:85-ov-00053-LFS Document 196 Filed 06/20/2008 Page 1 of 3
‘ O R I G I NA L ‘i§f§’tittf
2005* JUN 20 PH 3:1,1,
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Iames L. Martin, plaintiff : Civil Action No. 85-00053-LS
v. : jury Trial Demanded
Delaware Law School of Widener University, Inc., Commonwealth of
Pennsylvania Department of Transportation, Bureau of Traffic Safety
Operations, et. al., defendants
Plaintiffs Memorandum of Law in support of
Motion for Reargument of Motion to Reopen
ALLEGATIONS OF FACT S
I, james L. Martin, certify the following statements to be true to the best
of my knowledge and information this 20th day of Iune 2008, and further
certify that they are made under oath in accord with 28 USC Sec. 1746:
1. The event to warrant the Motion to Reopen began on 5-24-07, and
the decisiorfs focus on the "Background" is misplaced.
2. Judge Farnan’s involvement would be continuing now but for his
nexus to the principal defendant, when he was a paid staff member and
misrepresented his involvement on that point for several years, despite an
unappealed, final administrative judgment against the same principal
defendant.
3- At a hearing on 10-9-07, in New lersey, the presiding judge read the
file, explained that the case was mishandled by the court administrator, and
offered to take measures to correct certain official records in Trenton. The

Case 1 :85-cv—00053-LFS Document 196 Filed 06/20/2008 Page 2 of 3
issues there may also relate to this case insofar as the New lersey transcript,
just issued on 6-9-08, is certified as a ”co1npressed” transcript. In fact, the
transcript was truncated, so that only the introduction for the hearing was
transcribed.
4. The State of New Iersey told the presiding judge it is an “unusual
situation."
5. The contents of the entire transcript will be made available as soon as
they are issued.
6. The cover page correctly reads: ”TRANSCRIPT ORDERED BY:
SENATE, STATE OF DELAWARE, Legislative Hall, Dover, Delaware 19903.”
VVhy would the Delaware State Senate squander resources on a ”frivolous”
case?
CONCLUSION
This motion for reargument of the motion to reopen should be
granted, in view of the continuing need to clarify the record, compel the
defendants to restore various rights taken for many years without notice,
hearing, or cause, and to pay extensive damages, attorney’s fees, costs, and
prejudgment interest as well.
DATED: june 20, 2008
BY¤../ir.?.:1a<..r·:41.sf:;li/(cuphea ....__._.__
Iames attorney; 805 W. 21st SL.; Wilmington, DE 19802-3818
·‘e—mail MARTIN][email protected] (302) 652-3957
2

` Case 1 :85-cv—00053-LFS Document 196 Filed 06/20/2008 Page 3 of 3
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
lames L. Martin, plaintiff : Civil Action No. 85-0005-LS
v. : ]u.ry Trial Dernanded
Delaware Law School of Widener University, Inc., Commonwealth of
Pennsylvania Department of Transportation, Bureau of Traffic Safety
Operations, et. al., defendants
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of Plaintiffs
Plaintiffs Memorandum of Law in Support of Motion for Reargument of
Motion to Reopen upon the remaining opposing counsel of record for the
defendants at the following address:
Somers Price, ]r., Esq.; POTTER, ANDERSON 8: CORROON; P. O. Box
951; Wilmington, DE 19899
by first-class, postage prepaid mail this 20th day of Iune 2008.
A ·' ‘
BYr ‘ ‘@J;11L¤.4;i.-a(;Jr_lfl%L./L{Zt»a ......e“_.........___
]ames `l;£Martin, attorney; 05 W. 21 st St.; Wilmington, DE 19802-3818
(i 2) 652-3957 email MARTIN]ll\4I,@aoI.com