Free Motion to Stay - District Court of Delaware - Delaware

Case 1 :04-cv-00419-JJF Document 39 Filed 08/30/2005 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
@0 FOR THE DISTRICT OF DELAWARE
Cathy D. Brooks—McCollum CIVIL ACTION NO: 04-419 (JJF)
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRIAL REQUESTED
As a Director
ll5 Emerald Ridge Drive j { <——
f§‘i§`5;‘§£-é232‘ '1
(PLAINTIFF) P ` i``` D ` T ,
State Farm Insurance Company IC'! CO T
(DEFENDANTS) Dl ~° nrt i g __l
MOTION/OBJECTION & STAY
Plaintiffs hereby files this Motion, Objection and Stay of Actions in these proceedings until such time the
US Court Of Appeals rules on which court has jurisdiction over the issues in Civil Action 05-1264 and/or the
Delaware State Courts corrects its’ error should the US Court Of Appeals remand items back to the Delaware
State Court, and/or an appeal is perfected to either the Delaware Supreme Court and/or the US Supreme Court on
the error made by the Delaware Chancery Court, and/or an appeal is perfected regarding Civil Action
04-l4l9(JJF) against the State Of Delaware, Chancery Court, and Donald Parsons, to the US Court Of Appeals
and then to the US Supreme Court regarding the issues not addressed brought against the parties in Civil Action
04-l4l9(JJF) and the crimes they committed against all Plaintiffs in those proceedings, since the US District
Court states it cannot make the lower court adhere to the law, then if the US Court Appeals that it too camiot
make the lower court adhere to the law, the US Supreme Court surely will be able to.
Whereby, Plaintiffs files this motion as not to continue to have their constitutional rights violated at every
stage and the courts continuing to argue cases for Defendants in these cases, who can’t seem to argue their own
cases.
The appeal to the US Court Of Appeals against the State Of Delaware, et.al will be perfected prior to the
expiration of the 30-day time limit.
1

_ Case 1 :04-cv-00419-JJF Document 39 Filed 08/30/2005 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Cathy D. Brooks-McCollum CIVIL ACTION NO: 04-419 (JJF)
& On behalf of
Emerald Ridge Service Corporation Derivative Action JURY TRIAL REQUESTED
As a Director
1 15 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694
(PLAINTIFF)
vs.
State Farm Insurance Company
(DEFENDANTS)
PROOF OF SERVICE
I Cathy D. Brooks-McCollum hereby certify that on the 28th day of August, 2004, I will and have caused
to be served a true and correct copy of the foregoing Motion regular postage mail, postage prepaid and facsimile
upon defendants:
Casarino, Christman & Shalk
Stephen P. Casarino
800 North King St, Suite 200 J
P.O. Box 1276
Wilmington, DE 19899
(302) 594-4500
(302) 594-4509 Fax
Cathy D. rocks- cCo um (Pro Se)
115 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694

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Case/1504-t:‘=00419-JJF Docgnent 39 Filed 08/30/2005 Page30f3
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Case 1:04-cv-00419-JJF

Document 39

Filed 08/30/2005

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