Free Motion for Summary Judgment - District Court of Delaware - Delaware

Case 1:04-cv-00921-SLR

Document 151

Filed 09/02/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE VURNIS L. GILLIS, Plaintiff, v. STAN TAYLOR, et al., Defendants. ) ) ) ) ) ) ) ) ) )

Civil Action No. 04-921-SLR Jury Trial Requested

STATE DEFENDANTS' MOTION FOR SUMMARY JUDGMENT COMES NOW, State Defendants Stanley Taylor, Paul Howard, Thomas Carroll, Elizabeth Burris, and Jim Simms (the "State Defendants"), by and through their undersigned counsel, and hereby move this Honorable Court (the "Motion") to enter an Order granting summary judgment in their favor and against the Plaintiff as to all claims against them pursuant to Rule 56(c) of the Federal Rules of Civil Procedure. State Defendants have filed simultaneously herewith an Opening Brief in Support of Their Motion for Summary Judgment. WHEREFORE, State Defendants respectfully request that this Honorable Court enter an order granting summary judgment in their favor and against the Plaintiff as to all claims. STATE OF DELAWARE DEPARTMENT OF JUSTICE /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General 820 N. French Street Wilmington, DE 19801 (302) 577-8400 Attorney for the State Defendants

Dated: September 2, 2008

Case 1:04-cv-00921-SLR

Document 151

Filed 09/02/2008

Page 2 of 2

CERTIFICATE OF SERVICE
I, Erika Y. Tross, Esq., hereby certify that on September 2, 2008, I caused a true and correct copy of the attached State Defendants' Motion for Summary Judgment to be served on the following individual in the form and manner indicated:

VIA ELECTRONIC DELIVERY & FIRST CLASS MAIL: Zhun Lu, Esq. Connolly, Bove, Lodge & Hutz, LLP 1007 North Orange Street Post Office Box 2207 Wilmington, DE 19899 /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General Delaware Department of Justice Carvel State Office Building 820 N. French Street, 6th Floor Wilmington, DE 19801 302-577-8400