Free Motion for Reconsideration - District Court of Delaware - Delaware

,. Case 1:04-cv-01422-G|\/IS Document 24 Filed 06/06/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE WN ___ y NJ_
)
JEROME K. HAMILTON,a.k.a. )
CHEIKH AHMED ELOHIM, )
) Civil Action No.O4—l422-GMS*
PLAINTIFF. )
V.
CATHY L_ GUESSFORDI Et a1_’ 5 Motion For Reconsideration For Appointment
) Of Trained Counsel.
DEFENDANT'S. )
)
MOTION FOR RECONSIDERATION FOR APPOINTMENT
OF TRAINED COUNSEL.
Plaintiff Jerome K. Hamilton/Pro Se, being first duly sword,
hereby declares under penalty of perjury states the following: That Plainti-
-ff, is disabled senior citizen who cant work a real job concerning health -
reason's, due to the nightmares and flashbacks cause by the defendant's ill-
—egally and unconstitutionally imprisoned for a period of four years and six-
-ty-eight days. Plaintiff, is not able to afford private counsel to represen-
-t plaintiff in above-captioned case.
Comes Now, Plaintiff Jerome K. Hamilton/Pro Se, hereby
respectfully request and move this Honorable Court in its discretion should -
grant plaintiff motion and appointment of trained counsel to represent plaint-
-iff in above-captioned case who is an indigent civil litigant. See: 28 U.S.-
-C.A. & l9l5(e)(l)(West 1998). Also Plaintiff, circumstance's warrant a appoi- ,
-ntment of trained counsel, because plaintiff is having difficulty, concentr— l
-ating, flashbacks and nightmares which are affecting plaintiff functioning.- I
See: (ATTACHED EXHIBIT- A). That document is from plaintiff, Doctor/Psychiat-
—rist/P.D. Lifrak, M.D.,
THE GROUNDS FOR THIS MOTION ARE:
1. Plaintiff Jerome K. Hamilton/Pro Se, want to raised for {
the record respectfully request that this Honorable Court to take judicial - f
notice, that plaintiff is taking mental health medication's like Seroquel/25- Y
-MG, ETC. This medication's have cause plaintiff, not to adequately have the Q
ability to pursue an written deposition; FED.R.CIV.P.33(interrogatories); and Q
FED.R.CIV.P.34(document requests);FED.R.CIV.P.36(requests for admissions).The ?
plaintiff, doctor name is or under their care are: Doctor/P.D. Lifrak, M.D. - f
Community Plaza-287 Christiana RD.-Suite 8- New Castle,Delaware.l9720/and/ - ‘
address one of my doctor office are: Doctor/P.D. Lifrak,M.D.,-1701 Shallcross i
—Avenue,-Suite A —Wilmington,Delaware.19806. See:(Attached Exhibit-A) ........ I
1.

. · Case 1:04-cv-01422-G|\/IS Document 24 Filed 06/06/2005 Page 2 of 4
2. Plaintiff Jerome K. Hamilton/Pro Se, want to raised for
this motion on record respectfully request that this Honorable Court to take
judicial notice, that plaintiff case will need a factual investigation needed
in this matter does appear so extensive at this stage to warrant the appointm-
-ent of trained counsel. Finally Plaintiff, believe that Hamilton's case will
turn on credibility determination which will require expert testimony. Plaint-
—iff, feel that the time have arise, the court should entertain plaintiff re-
—consideration motion for appointment for trained counsel at this time. Becau-
—se Doctor/P.D# Lifrak, M.D. on June 2,2005 stated plaintiff is having diffic-
—ulty, concentrating, cause by flashbacks and nightmars which are affecting -
plaintiff thinking and functioning. See:(Attached Exhibit-A).
Wherefore, The Plaintiff Jerome K. Hamilton/Pro Se,is ent-
-itle for relief hereby respectfully requests this Honorable Court to enter -
an order in its discretion by granting plaintiff motion for reconsideration -
for appointment of trained counsel to represent plaintiff in above-captioned -
case who is an indigent civil litigant. See: 28 U.S.C.A. & l9l5(e)(l)(West 19-
-98). Another reason why plaintiff should received a trained counsel, because
plaintiff is suffering difficulty, concentrating, from flashbacks and nightma-
-res which are affecting his thinking functioning. See:(Attached Exhibit—A)..
Plaintiff, seriously believe that his case do warrant appointment of counsel -
because the defendant's take the plaintiff liberty illegally and unconstituti-
—onally imprisonment for a period of four years and sixty—eight days.
Dated: June 3,2005. Respectfully Submitted i
Plaintiff/Jerome K, Hgmé ton 2
Pro Se,j hEZ,djLmwL £@§? .
a.k.a./Cheikh Ahmed Elohim
320 East Fifth Street/Apt.609
Wilmington,Delaware.19801
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Case 1:04-cv-01422-G|\/IS Document 24 Filed 06/06/2005 Page 3 of 4
P. D. LIFRAK. MD.
1701 SHALLGROSS AVENUE. SURTE A
WILMINGTON. DE 19806
TELEPHONE (SO2) 654-7317 DEA REG. N0. BL179329O
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Exhibit- A

- T · Case1:04—cv-01422-GMS Document 24 Filed 06/06/2005 Page40f4
— Certificate Of Service —
)
State 0f Delaware ) SS,
New Castle County )
)
BE IT REMEMBER, that Plaintiff Jerome K. Hamilton/Pro Se
being first duly sworn according to law and the penalty of perjury, on the —
or this 3th , day of ggne 2005, placed in the U.S. mail . Two true and cor-
-rect copies of the attached: Motion For Reconsideration For Appointment Of
Trained Counsel. And this document will be sent to the below person‘s.
l. Peter T. Dalleo, Clerk
Clerk of the Court
United States District Court
844 King Street
J.Caleb Boggs Federal Building
Wilmington,Delaware.19801
2. Eileen Kelly,I.D.#2884
Deputy Attorny General
Carvel State Office Building
820 North French Street,6th Floor.
Wilmington,Delaware.19801
3. Plaintiff/Jerome K. Hamilton,Pro Se,
a.k.a., CHEIKH AHMED ELOHIM
320 East Fifth Street/Apt.#609
Wilmington,Delaware.19801
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