Free Answering Brief in Opposition - District Court of Delaware - Delaware

if Case 1 :07-cv—00530-SLR-LPS Document 22 Filed 07/25/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOHN O. FRINK, )
Plaintiff, ) CIV. N0. : 07-530 SLR LPS
)
v. )
)
THOMAS MACLEISH, ET. AL., )
Defendants. )
PLAINTIFF’S ANSWERING BRIEF IN RESPONSE TO
CERTAIN DEF ENDANTS’ MOTION TO DISMISS THE COMPLAINT
For the following reasons, I respectfully request that the Complaint in this matter not be
dismissed.
1. This incident was the result of the Defendants unnecessary and unreasonable
negligence and could have been avoided;
2. I received permanent and life threatening injuries as a result of the Defendants
negligence and will have to live with these injuries for the remainder of my life. Also, I will incur
future medical expenses as a result of this incident;
WHEREFORE, for the reasons stated above, I respectfully request that the Complaint not
be dismissed and that this matter proceed to a jury trial.
1 * .~ ~
JOHN O. FRINK
Plaintiff, Pro Se
Date: July 25, 2008
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— Case 1:07-cv—00530-SLR-LPS Document 22 Filed 07/25/2008 Page 2 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOHN O. FRINK, )
Plaintiff, ) CIV. N0. : 07-530 SLR LPS
)
v. )
)
THOMAS MACLEISH, ET. AL., )
Defendants. )
CERTIFICATE OF SERVICE
The undersigned hereby certifies that 1 copy of the attached
PLAINTIFF’S ANSWERING BRIEF IN RESPONSE TO CERTAIN DEFENDANTS’
MOTION TO DISMISS THE COMPLAINT
was served on July 25, 2008, by hand delivering and/or mailing to:
Stephani Ballard, Esquire
Department of Justice
820 French Street, 6“‘ Floor
Wilmington, DE 19801
JOHN O. FRINK
Plaintifi Pro Se

Case 1:07-cv-00530-SLR-LPS

Document 22

Filed 07/25/2008

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Case 1:07-cv-00530-SLR-LPS

Document 22

Filed 07/25/2008

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