Free Motion to Dismiss - District Court of Delaware - Delaware

Case 1:04-cv-00209-SLR

Document 37-2

Filed 03/03/2006

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WILLIAM F. DAVIS, III v. CORRECTIONAL MEDICAL SERVICES, INC. (incorrectly designated as "Correctional Medical Systems"), et al. ) ) ) ) ) ) ) ) C. A. No. 04-209-SLR TRIAL BY JURY OF TWELVE DEMANDED

MOTION OF DEFENDANT, CORRECTIONAL MEDICAL SERVICES, INC. (incorrectly designated as "CORRECTIONAL MEDICAL SYSTEMS") TO DISMISS PLAINTIFF'S COMPLAINT

Defendant, Correctional Medical Services, Inc. (incorrectly designated as "Correctional Medical Systems") ("CMS"), through its undersigned attorneys, hereby moves for dismissal of plaintiff's Complaint for the reasons set forth in the accompanying Memorandum of Points and Authorities. WHEREFORE, defendant, Correctional Medical Services, Inc. (incorrectly designated as "Correctional Medical Systems"), respectfully moves this Honorable Court to enter the attached Order, granting its Motion to Dismiss Plaintiff's Complaint. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: /s/ Kevin J. Connors Kevin J. Connors, Esquire #2135 1220 North Market Street, 5th Fl. P.O. Box 8888 Wilmington, DE 19899-8888 Attorney for Defendant, Correctional Medical Services, Inc. (incorrectly designated as "Correctional Medical Systems") Dated: March 3, 2006
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