Free Letter - District Court of Delaware - Delaware

, , Case 1:04-cv-01422-GIVIS Document 27 Filed 06/29/2005 Page 1 of 3
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I;>§A?%" IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
From: Mr. Jerome K. Hamilton
a.k.a.,Cheikh A.Elohim
Pro/Se:
320 East Fifth Street/Apt.609
wi1mington,Delaware.19801
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Dated: June 25,2005 gg gig
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The Honorable Gregory M. Sleet gg _§@§7
United States District Court gg :§%E
United States Courthouse Q? §§{
844 King Street/Lockbox 19 EQ 1@§§
Wilmingt0n,Delaware.19801 "1
RE: Hamilton v. Guessford, et al;
Civil Action No.O4—l422-GMS*
Dear Judge Sleet:
I'm writing you this letter on the behalf of plaintiff,-
concerning additional facts and relevant evidence that should be made apart of
the record for future reference's. About Plaintiff, chronic lower bach pain w-
-hich is also affecting plaintiff concentrating and thinking process, because -
i am on medication like (PERCOCET/7.5-325M).
1. Plaintiff Jerome K. Hamilton/Pro Se, hereby respectf-
—ully request this Honorable Court to take judicial notice. That Plaintiff, is
requesting this court to allowed plaintiff, to amend his complaint to add the —
(Department of Corrections), as a defendant did unlawfully imprisonment of the
plaintiff four years and sixty-eight days. See:(Attached Exhibit- A). Plaintif-
—f, want and request this court for judicial review of Judge Toliver, decision
on May 16,2003 order the Department of Correction to recalculate the plaintiff
release date. See:(Attached Exhibit- A). Plaintiff Hami1ton,believe this matter
need to be a investigation for factual relvance to their misconduct against the
plaintiff.
2. Plaintiff Jerome K. Hamilton/PIO Se, hereby respectfu-
-1ly request this Honorable Court to take judicial notice. That Plaintiff, is
requesting this court to allowed plaintiff, to amend his complaint to the or -
add the (State Of Delaware) as defendantbecause they had role of taking plaint-
-iff liberty unlawfully imprisonment, by agreeing with the misconduct of Defen-
-dant/Guessford, and Defendant/McBride, on March 31,2000. This next document -
is relevant to show that (State 0f Delaware), did unlawfully imprisonment of —
plaintiff four years and sixty—eight days. See:(Attached Exhibit-B). Plaintiff,
believe this matter need to be a investigation to show their involvement to -
prived plaintiff of his libery.
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. _ Case 1:04-cv-01422-G|\/IS Document 27 Filed 06/29/2005 Page 2 of 3
3. Plaintiff Jerome K. Hamilton/Pro Se, want to raised and
make a record for future reference, respectfully request this Honorable Court,
to take judicial notice and acknowledge the following. Plaintiff had help when
compose the complaint and filing on November 5,2004. See:(D.I.2). Because the
plaintiff, was experiencing and having difficulty concentrating and his inabil-
—ity to function has affected there thinking by flashbacks, nightmares and ment-
-al health medications which started once again on March 1,2004 and on March -
- 27,2004. The next document are medical records information. See;(Attached -
- Exhibit- "C").
4. Plaintiff Jerome K. Hamilton/Pro Se, want to raised and
make a record for future reference, respectfully request this Honorable Court-
to take judicial notice and acknowledge the following facts. Plaintiff had help
when he compose the filed Request for Default on March 1,2005 See:(D.I.19).The
Plaintiff, doesn't have the knowledge or the skills to represent himself, beca-
-use he is taking mental health medications which is affacting there thinking-
medications which started once again on March 27,2004. The next document are a
part of plaintiff medical records information. See:(Attached Exhibit- "C").A1so
Plaintiff, is taking medication because he has chronic lower back pain and the
medication their taking are.(Orycod/Apap-Generic For Percocet 7.5-325M). The -
next document are medical records information from Doctor Jose M. Castro,M.D.»
see:(Atta¤ned Exhibit- "D").
5. Plaintiff Jerome K. Hamilton/Pro Se, want to raised and
make apart of the record for future reference, respectfully request this Honor-
-able Court to take judicial notice and acknowledge the following facts. That -
plaintiff, need some professional help to handle the above-captioned case beca-
-use plaintiff have been and still is experiencing chronic lower back pain. And
the medication plaintiff is taking are affecting his concentration and thinking
are.(Orycod/Apap-Generic For Percocet 7.5-325M). The next document are plainti-
-ff medical records information facts from, Doctor Jose M. Castro,M.D., on the
June 24,2005. See:(Attached Exhibit- “D").
6. Plaintiff Jerome K. Hamilton/Pro Se, want to raised and
make apart of the record for future reference, respectfully request this Honor-
-able Court to take judicial notice and acknowledge the following facts. Plain-
-tiff doesn't have the knowledge or the skills to compose any type of written-
discovery in this case, because plaintiff is taking several type of medication
which is affecting his concentration and thinking ability. The medications are
plaintiff medical records information provide by Doctor Lifrak,M.D. and Doctor-
-Castro,M.D.. See:(Attached Exhibit- "C"). And also see the plaintiff, medical-
-records information document from,Doctor Castro,M.D. See:(Attached Exhibit-D).
7. Plaintiff Jerome K. Hamilton/Pro Se, want to raised and
make apart of the record for future reference, respectfully request this Honor-
-able Court to take judicial notice and acknowledge the following facts. Plai-
-ntiff can show from record he was on mental health medications on July 16,1999
and the (Department of Corrections), can also prove this fact from there recor-
—ds when plaintiff was incarcerated in prison. Plaintiff can show that his com-
—plaints began, about his "difficulty concentrating, flashbacks and nightmares
affects did started once again before and on July 16,1999. Plaintiff believe
that this fact need a investigation on this matter immediately by the c0urt...
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~ . Case 1:04-cv-01422-G|\/IS Document 27 Filed 06/29/2005 Page 3 of 3
Wherefore, the Plaintiff Jerome K. Hamilton/Pro Se, -
hereby respectfully request this Honorable Court to take judicial notice and
acknowledge the following facts. That Plaintiff, difficulty concentrating and
functioning mentaling and physically because of the medications that plainti-
-ff is taking from. Doctor Lifrak,M.D./and/Doctor Castro,M.D. See:£Attached—
-Exhibit—"C"). And also. See:(Attached Exhibit-'D"). Now Plaintiff, move this
Honorable Court in its discretion should grant plaintiff motion or request —
for appointment of trained counsel to represent plaintiff merits claims in t-
—he above—captioned case matter who is an indigent civil litigate. See: 28 U.-
-S.C.A. & l9l5(e)(l)(West 1998). Also because of the plaintiff mental state-
sufficiently disabling him to bring this matter to this court adequately whic-
-h warrant appointment of counsel according to law under. See: Hamilton v. -
;Leavy,l17 F.3d 742(3rd Cir.l997). Plaintiff believe he is entitled to this —
type of relief.
Dated: June 25,2005 Respectfully Submitted
Plaintiff/Jerome K. Hamilton
a.k.a./Che`h A. Eiggig;
Pro Se: " Ad,
320 East Fifth Street/Apt.609
Wilmington,Delaware.19801
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