Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1:04-cv—00209—SLR Document 23 Filed 06/29/2005 Page1 of3
I IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WILLIAM F. DAVIS, III, :
Plaintiff, :
V. : Civ No. 04-209-SLR
RAPHAEL WILLIAMS, (FNU) ROBINSON;
BETTY (LNU),
Defendant(s). . MOTION TO AMEND
: per RULE 15 of F.R. of Civ.
Procedure
. and
U MOTION FOR AN INJUNCTION
: per RULE 65 (b)
As ORDERED on the 25th day of April, 2005; by United States District
Judge SUE L. ROBINSON, the above named Plaintiff respectfully
moves to AMEND the above captioned Civil Action, specifically
to NAME all Defendant(s) as opposed to naming Correctional Medical
Systems, First Correctional Medical, and Department of Corrections
as in the original Complaint.
Further; Plaintiff moves for this Honorable Court to
issue an INJUNCTION against Defendant Raphael Williams, Warden of
the Howard R. Young Correctional Institution, and his staff for
possible retaliation for two (2) Lawsuits against them.
William F. Davis, III
SBI# 162762
Howard R. Young Correctional Inst.
P.O. Box 9561
Wilmington, DE 19809
Plaintiff, Pro Se.

Case 1:04-cv—00209—SLR Document 23 Filed 06/29/2005 Page 2 of 3
I Defendant Raphael Williams is employed as Warden at
the Howard R. Young Corredtional Institution; (Hereinafter cited
as H.R.Y.C.I,), P.0, Box 9561, Wilmington, DE 19809.
Defendant (FNU) Robinson was employed as the resident
Doctor for First Correctional Medical ate the H.R.Y.C.I., P.O.
Box 9561, Wilmington, DE 19809, at the time of the initial
incident(s) occured.
Defendant Betty (LNU) was employed as a NQRSE for both
Correctional Medical Systems (CMS) and First Correctional Medical
(FCM), at the H.R.Y.C.I., P.O. Box 9651, Wilmington, DE 19809.
Plaintiff will further rely on all materials previously
submitted pertaing to the original COMPLAINT, as well as any other
subsequent pleadings, statements, and letters relationg to P1aintiff's
claim(s) in further support of this instant motion to AMEND.
Plaintiff further moves to have this Honoragle Court to
issue an INJUNCTION against Warden Williams and his Staff for
possible retailation and harassment for filing two (2) lawsuits
against them, and further asking the Court to TRANSFER Plaintiff
to S.C.I.G.,(State Correctional Institution at Georgetown) so that
Plaintiff can complete doing his time in peace.
I CERTIFY that the forgoing statements made by me are
true. I am aware that if any of the foregoing statements made by
me are willfully false, I am subject to punishment by law.
Respectfully submitted,
._ A · · , _. _

Case 1:04-cv—00209—SLR Document 23 Filed 06/29/2005 Page 3 of 3
CERTIFICATE OF SERVICE
W I, william F. Davis, III , hereby swear under penalty of
perjury that I have rendered service of a true and correct
cop(ies) of the attached:
MOTION TO AMEND AND MOTION REQUESTINQ AN [NgH§g||QN
(Title or Type of Motion or Request)
new
upon the following person{s) and/or agency(ies):

Attorney General, Wilmington,
Delaware. Counsel for Depart—
ment of Corrections. .
I Daniel L. McKenty, Esq.,
McCullough & McKenty, P.A.,
Wilmington, DE. Counsel for
Defendant First Correctional
Medical.
EY PLACING SAME IN A SEALED ENVELOPE, postage will be paid by the
Delaware Department of Corrections/Pre-paid, and depositing same
in the United States Mail at the Multipurpose Criminal Justice
Facility, 1301 East 12th Street, Wilmington, Delaware.
On this day of , 200__.
(Your signature)

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