Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-OO175—JJF Document 110 Filed O9/O@R]€§`:WFlage 1 of 3
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Good morning and afternoon to all parties of Federal Civil Case: 04-l75—KAJ.
On 8-l8—06 per Conference discussion of some issues was handled with concern
in the Teleconference, meaning my concern of stating a position to where I the
Plaintiff stands on Mr. Griffith's sudden Request for a Jury Trial has been deeply
considered, and for the Record I will now respectfully submit my position today
on 8-25-06, seven days after the 8—l8—06 Conference for which I have adhered to
the 2- week Order to allow disposition.
g with all due respect to Mr. Griffith,my position is clearly to be presented
as great opposition and ask that the request of jury trial be denied with prejudice.
Due to the fact after a three year mark is very near that such procedures of
jury trial is in fact way out of context to any preparation. Scheduling Order is
set for a 2 day Bench Trial for which was set with no dispute of Civ. Fed. Case:
O4—l75-KAJ in the entire case going on 3 years now is not the time to create a
strategy for trickery and chaos motivating a dilatory defense. 'Poor strategic
planning is not an excuse three years laterzl the Plaintiff would have absolutely
no objections at all if we were at the initial disclosures preocedure which was
the first scheduling Order number l of Nov. l8, 2004, but the facts are,for almost
3 years all parties indicated no signs of stress or uncomfortability of having this
case tried by Honorable Judge Kent A. Jordan. The entire firm even when William
W. Pepper was representing Dover Police Dept. the entire firm of Daniel A. Griffith,
Marshall, Dennehey, Warner, Coleman and Goggin has never ever had any dispute to
have Honorable Judge Kent A. Jordan weigh the evidence and facts of this case and
try it. I the Plaintiff certainly has not ever questioned the judge's ability or
honesty to allow justice to prevail!! I again state for the Record I oppose and
deeply strive against the Defendahts' Request to a Jury Trial.
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Case 1 :04-cv-00175-JJF Document 110 Filed O9/O1/2006 Page 2 of 3
·_ _ CERTIFICATE OF SERVICE p `
_ I, • ‘ L · CUP hereby certify that I have served atrue and
correct copy ofthe attached an- , · 4;% •3L?a-aaa an , ` · upon the
following person/s below: _ y i I
- . - NAME ‘ . STREET CITYISTATE/ZIP
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_ · ‘_ _ By placing same in a sealed,lp0stage‘ pre-paid envelope and depositing S&II1¤ in
the United States Mail at Sussex Correctional Institution, 1*.0. Box 500, Georgetown,
‘ I Delaware 19947, I .
_ t . _ This lh dayiof [Lggmix ,_ _

Case 1 :04-cv-00175-JJF Document 110 Filed O9/O1/2006 Page 3 of 3
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Case 1:04-cv-00175-JJF

Document 110

Filed 09/01/2006

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Document 110

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