Free Response to Motion - District Court of Delaware - Delaware

Case 1 :07-cv—00465-SLR Document 9 Filed 10/09/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III, :
Plaintiff,
: C.A. No. C.A. No. 07-465-SLR
v. :
CHRISTOPHER A. COONS,
individually and in his official capacity; : l
RICHARD PRZYWARA, individually : JURY TRIAL DEMANDED
and in his official capacity; and :
NEW CASTLE COUNTY, a municipal :
corporation, :
Defendants.
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
Plaintiff, through his imdersigned counsel, respectfully opposes Defendants’ Motion to
Dismiss in the a"oove—captioned case. The grounds for his opposition are set forth in Plaintiff s
Answering Brief in Opposition to Defendants’ Motion to Dismiss, which is filed separately.
Re -•ectfu y s tte y _`
Ti J. { _.•n, E . (DE #43
Jeffrey . M Esq. (DE #2407)
1508 B ennsyl /. ia Avenue
Wil ngton, el 19806
(302) 777-4 81 — telephone
[email protected]
[email protected]
Attorneys for Plaimyjf
Dated: October 9, 2007

Case 1:07-cv—00465-SLR Document 9 Filed 10/09/2007 Page 2 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III, :
Plaintiff,
: C.A. No. C.A. N0. 07—465-SLR
v. :
CHRISTOPHER A. COONS, I
individually and in his official capacity; :
RICHARD PRZYWARA, individually : JURY TRIAL DEMANDED
and in his official capacity; and :
NEW CASTLE COUNTY, a municipal :
corporation, :
Defendants.
CERTIFICATE OF SERVICE
I, Timothy J. Wilson, do hereby certify that on this 9th day of October, 2007, a true and
correct copy ofthe attached Plaintiff s Opposition to Defendants° Motion to Disrniss was
ELECTRONICALLY Filed and copied to:
Richard R. Wier, Jr., Esq. (#716)
1 Two Mill Road, Suite 200 -
Wilmington, DE 19806
`mu, I “ fj;j; L
Timo J. W` son, . (DE #4323)
Jeffrey '¤ . Martin, E (DE #2407)
1508 Pe sylvania · nue
Wilmin on, DE H.
(302) 7 -4681 —te1e hone
[email protected]
jmartin@n1a1·tir1andt»\rilson.com
Attorneys for Plaintpf
Dated: October 9, 2007