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

Case 1:05-cv-00345-SLR Document 11 Filed 07/19/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Civil Action No. 05-345-SLR
Plaintiffs Motion Reguesting Appointment of Outside Legal Counsel
Before Ruling On Defendant’s Motion To Dismiss
Summagyz Up to this date, 19 July 2006, I, James N. Patnaude, the Plaintiffin the above
cited civil action, have been representing myselfin this matter. My Pro Se status is out of
necessity not choice because of my current financial situation. I recently received two (2)
documents; the first, a "Defendant’s Motion To Dismiss For Failure To State a Claim",
and the second, an "Opening Briefln Support Of Defendant’s Motion To Dismiss". Both
documents were drafted by Assistant United States Attorney (AUSA) Seth M. Beasang
from the U.S. Attorney’s office in Delaware. Both documents were dated ll July 2006
and received via United States Postal Service shortly thereafter. I am aware that some
type of response or action is required to convince the court not to dismiss my case at this
time.
Action Reguested By The Plaintiff: I am acutely aware that because of my inadequate
knowledge of court procedure and process, I am unable to adequately address the issues
raised by the AUSA in the above mentioned documents. The Plaintiff respectively
requests that the court appoint outside legal counsel with experience in the particular area
of law that my case addresses. (
Reasoning For Reguest: At the beginning ofthis process I was informed by the Equal
Employment Opportunity (EEO) Unit at the Headquarters ofthe Federal Bureau of
Investigation (FBI) that if my claim progressed to filing a civil suit in United States
District Court, that legal counsel would be provided. In addition, after exhausting my
attempt of the review of my claims by the Department of Justice Adjudication Unit, I was
informed that should I proceed with filing a civil suit in United States District Court,
legal counsel would be provided ifl could demonstrate a financial need for such
appointment. If the court would like to review these documents I will provide copies
immediately upon notification.
Documentation Of Financial Need: Please see Attachment 1
As has been the case since my initial contact with the court, thank you for your time,
i consideration and patience in this matter. If the court requires any additional information
or documentatjdn regarding this matter please contact me at your earliest convenience.
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flliiiies N. Patnaude § f
aintiff Case # 05-345-SLR _ ‘ ·
July I9, 2006 "° 35}}
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Case 1:05-cv-00345-SLR Document 11 Filed 07/19/2006 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Civil Action No. 05-345-SLR
Attachment 1
Summary Of Current Assets:
(All amount areas of 07/1 9/2006 and rounded to the nearest hundred)
Checking Account 1 $43,000
Checking Account 2 300
Total $42,300
Summary Of Current Liabilities:
(All amount areas of 07/19/2006 and rounded to the nearest hundred)
Credit Card Debt $23,400
Promissory Notes 6,500
Medical Bills 565
Legal Bills 7,200
Child Support (Current Month) 500
Total $38,165
Plaintiff also has a Thrift Savings Account. Withdraw from which results in substantial
penalty at this time. Plaintiff also owns a 2003 Saturn L200.
Plaintiff will provide any and all documentation immediately for the above listed
amounts. Plaintiff will also complete any documentation the court requests to verify that
the Plaintiff has no other assets.
Page 1 of 1
(Of Attachment 1)

Case 1:05-cv-00345-SLR Document 11 Filed 07/19/2006 Page 3 of 3
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