Free Motion to Appoint Counsel - District Court of Delaware - Delaware

_ Case 1 :07-cv-00448—G|\/IS Document 7 Filed 07/19/2007 Page 1 of 4
. ORIGINAL
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IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE
RUSSELL E. STEEDLEY, )
v. ) ` ' ' q
CORRECTIONIONAL MEDICAL SERVICES, Inc, et al, ) ,- ,-:,I1— -
Defendants. ) U ,_` _ U ‘___ _` Q
NOTICE OF AND MOTION FOR THE APPOINTMENT OF COUN ti F" .
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COMES NOW, PLAINTIFF RUSSELL E. STEEDLEY, pro se and gives notice {a j I _-J ,?
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H01'101'3bl€ Court that plaintiff is seeking appointment of counsel to mpi-ggem him in -`---i ~ `
captioned case. i ¤·~i · e ‘*‘‘‘ “‘ a n E
Plaintiff Russell E. Steedley, in pursuant to 28 U.S.C. Section 1915, requests this court to I
appoint counsel to represent him in this case for the following reasons:
I 1. Plaintiff lacks the financial resources to retain competent and experienced counsel. A
2. The legal and medical issues involved in this case are complex and plaintiff does not 1
have sufficient knowledge to prosecute his case before the court and accessibly to l i
germane medical material. i
3. Plaintiff; as an inmate at the Delaware Correctional Center (DCC), does not have access
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to the internet- filtered or limited to legal research Websites such as LEXIS and l
WESTLAW A in order to find applicable case law to support his allegations and
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arguments.
4. Plaintiff does not have open access to conventional and unrestricted telephone system, E- i
mail and fax in order to contact medical professionals; accredited and reputable agencies,
organizations and associations; and expert witnesses require for a jury trial. I

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.. Case 1:07-cv-00448-GIVIS Document 7 Filed 07/19/2007 Page 2 of 4
5. Plaintiff does not have the ability to investigate the facts; identity, questions and depose
of witnesses; and to access, analyze and take possession of copies of his medical records
from the Delaware Department of Corrections, CMS and/or any other Health Care
Provider due to his status as an inmate, administrative and corporate policies, rules, and
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regulations.
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DATED: /6 51.1 » M0?
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Russell Steedley - 1
SBI#249572, W-1, H-13 K
Delaware Correctional Center l r
1181 Paddock Rd
Smyrna,`DE 19977
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Case 1 :07-cv-00448—G|\/IS Document 7 Filed 07/19/2007 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
I RUSSELL E. STEEDLEY, ) p
Plaintiff, ) .
v. ) C.A.
CORRECTIONIONAL MEDICAL SERVICES, Inc, et al, )
Defendants. )
AFFIDAVIT IN SUPPORT OF PLAINTIFF’S MOTION FOR THE ‘
APPOINTMENT OF COUNSEL
RUSSELL E. STEEDLEY, being duly sworn, deposes and says: .
1. I am the plaintiff in the above entitled case. I make this affidavit in support of my
motion for the appointment of counsel.
I 2. The complaint in this case alleges that the defendants have been deliberately
indifferent and discriminatory toward plaintiff s need to receive full and adequate
treatment for his chronic Degenerative Joint Disease. He has been denied access to an
orthopedic surgeonf specialist. Plaintiff deteriorating joint condition and the adverse
affects produced by the treatment currently provided is negatively impacting the
plaintiff and is approaching to point where the damage may become irreversible.
3. The plaintiff has demanded a jury trial.
4. Plaintiff has extremely limited resources at his disposal; which severely limits his
ability to conduct the appropriate investigations, interview/depose witnesses and
l experts. U
5. Plaintiff is a layman ofthe law.
6. Plaint is also a layperson regarding the field of general medical practice.
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Case 1:07-cv-00448—G|\/IS Document 7 Filed 07/19/2007 Page 4 of 4
7. The case may require substantial discovery of documents and depositions and
subpoena of numerous witnesses.
WHEREFORE, the plaintiffs MOTION FOR THE APPOINTMENT OF COUNSEL
should be granted. 9
I declare under the penalty of perjury, pursuant to 28 U.S.C. Section 1746 and 18 U.S.C.
Section 1621, that the foregoing is true and correct.
Signed this { 6 day of gf l { , 2007 ‘
Russell Steédley
SBI#249572, W—1, H-13 _
Delaware Correctional Center l _
1181 Paddock Rd ` _
Smyrna, DE 19977 _ `
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