Free Motion to Consolidate Cases - District Court of Delaware - Delaware

Case 1:07-cv—00644-Gl\/IS Document 14 Filed 05/20/2008 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
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NINA SHAIHN, )
Plaintiff ) é
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v. ) C.A. No. 06-289 GMS
) C.A. No. 07-452 GMS
STATE OF DELAWARE, etal ) C.A. No. 07-641 GMS/LPS
) C.A. No. 07-642 GMS/LPS
) C.A. No. 07-643 GMS/LPS
Defendants, ) C.A. No. 07-644 GMS/LPS
PLAINTIFF’S MOTION TO JOIN OTHER PARTIES AND AMENDMENT OF
PLEADINGS
The Plaintiff; Nina Shahin, files this Motion to join all lawsuits filed against the
different agencies of the State of Delaware into one lawsuit. The Plaintiff also requests
the new schedule for discovery for all the above-mentioned lawsuits especially since she
worked as a Tax Manager of one of the busiest free tax preparation sites in the State of
Delaware and had no opportunity to do anything about the necessary actions for
discovery before the end of April, 2008.
The Plaintiff amends the pleadings for relief as follows: "The Plaintiff prays that
the Court grant relief as may be appropriate including injunctive orders, damages and
costs."
Submitted on this 16* day of May, 2008. fx
For the Plaintiff ............ ' .... .
Nina Shahin, CPA
103 Shinnccock Rd.
Dover, DE 19904
(302)678-1805
DATED: May 16, 2008

Case 1:07-cv—00644-G|\/IS Document 14 Filed 05/20/2008 Page 2 of 4
CERTIFICATE OF MAILHVG AND/OR DELIVERY
The undersigned certifies that on May 16, 2008, she caused the attached
Plaintiff` s Motion To Join Other Parties and Amendment of Pleadings to be delivered to
the following persons in the form and manner indicated:
NAME AND ADDRESS OF RECIPIENTS:
1. U.S. District Court
844 King Street
U.S. Courthouse
Wilmington, DE 19801
MANNER OF DELIVERY:
Original and a copy by certified mail with return receipt
2. Stephani J. Ballard, # 3481
Deputy Attomey General
Department of` Justice
State of Delaware
Carvel State Office Building
820 North French Street, 6th fl.
Wilmington, DE 19801
Attorney for Defendant
MANNER OF DELIVERY:
Two true copies by priority mail with confirmation of receipt
3. Laura L. Gerard
Deputy Attorney General
Department of Justice
State of Delaware
Carvel State Office Building
820 North French Street, 6th fl.
Wilmington, DE 19801
Attorney for Defendant
MANNER OF DELIVERY:
Two true copies by priority mail with confirmation of receipt
ii

Case 1:07-cv—00644-Gl\/IS Document 14 Filed 05/20/2008 Page 3 of 4
4. Frederick H. Schranck
Deputy Attorney General
800 Bay Rd., P.O. Box 778
Dover, DE 19903
Attorney for the Defendant
MANNER OF DELIVERY:
Two true copies by priority mail with confirmation of receipt
5. Beau Biden
Attorney General of the State of Delaware
820 North French Street,
Wilmington, DE 19801
Attorney for Defendant
MANNER OF DELIVERY:
Two true copies by priority mail with confirmation of receipt
6. John B. Hindman
Deputy Attorney General
102 West Water St., 3"’ Floor
Dover, DE 19004-6750
MANNER OF DELIVERY:
Two true copies by priority mail with coniirmation of receipt
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Nina Shahin
May 16, 2008
iii

Case 1:07-cv—00644-G|\/IS Document 14 Filed 05/20/2008 Page 4 0f 4
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Case 1:07-cv-00644-GMS

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