Free Motion to Dismiss for Failure to State a Claim - District Court of Delaware - Delaware

Case 1 :07-cv-00465-SLR Document 6 Filed 09/17/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III :
Plaintiff
: C.A. No. 07-465-SLR
v. :
CHRISTOPHER A. COONS,
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.
DEFENDANTS’ MOTION TO DISMISS
Defendants, through their undersigned counsel, respectfully move for Dismissal on all
counts of the Complaint of Demris E. Parkstone, III. The grounds for this Motion are set forth in
the Opening Brief in Support of Defendants’ Motion to Dismiss, which is tiled separately.
Respectfully submitted,
/s/ Richard R. Wier, Jr.
Richard R. Wier, Jr. ( #716)
Michele D. Allen (#4359)
Two Mill Road, Suite 200
Wilmington, DE 19806
[email protected]
302.888.3222
Attorney for Defendant
Dated: September 17, 2007

Case 1:07-cv-00465-SLR Document 6 Filed 09/17/2007 Page 2 of 2
IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III :
Plaintiff
: C.A. No. 07-465-SLR
v. :
CHRISTOPHER A. COONS,
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 certify that on this 17*** day of September, 2007 have caused a true and correct copy of
the attached Motion to Dismiss to be ELECTRONICALLY FILED, and copied to:
Timothy James Wilson, Esquire
Martin & Wilson, P.A.
1508 Pennsylvania Avenue
Wilmington, DE 19806
/s/ Richard R. Wier, Jr.
Richard R. Wier, Jr. ( #716)
Michele D. Allen (#4359)
Two Mill Road, Suite 200
Wilmington, DE 19806
[email protected]
302.888.3222
Attomey for Defendant
Dated: September 17, 2007

Case 1 :07-cv—00465-SLR Document 6-2 Filed 09/17/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III :
Plaintiff
: C.A. No. 07-465
v. :
CHRISTOPHER A. COONS, :
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. :
NOTICE OF MOTION
Please take notice that the Plaintiff s Motion to Dismiss will be presented to the Court at
the Court’s earliest convenience.
RICHARD R. WIER, JR., P.A.
/s/ Richard R. Wier, Jr.
Richard R. Wier, Jr., Esquire (#716)
Michele D. Allen, Esquire (#4359)
Two Mill Road, Suite 200
Wilmington, Delaware 19806
(302)888-3222

Case 1 :07-cv—00465-SLR Document 6-3 Filed 09/17/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF DELAWARE
DENNIS E. PARKSTONE, III :
Plaintiff
: C.A. No. 07-465
v. :
CHRISTOPHER A. COONS,
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.
ORDER
Upon Plaintiff s Motion to Dismiss in the above-captioned case,
IT IS ORDERED this Day of A.D. 2007 that:
Plaintiffs motion is GRANTED.
J.