Free Opening Brief in Support - District Court of Delaware - Delaware


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Case 1:98-cv—00197-SLR Document 326-4 Filed 11/13/2006 Page 1 013

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coin, to create a new bulletin coin (rollcall CONGRATULATIONS TO MARY- Maryville mayor Joe Swann had a
624); Ort motion to suspend the rules and VILLE HIGH SCHO()I_,’S RED "ohAqoo"s}tuat1o1n on his hands. h
ass, as amended, rm. 3422, me Small Pub- REBEL FOOTBALL TEAM . 9*,9 WP G We we A S“%“° ° em-
P . . pionship, Swann said. These kids get a
lic Housing Authority Act (rollcall 625). Had l — ohonoo to ooiobmoo eogoohoo
been present I would havovoto "yoo" on all HON. JOHN J. DUNCAN, JR. "They’ve beth accomplished something
3 measures. OF TENNESSEE that’s really remarkable. It’ll make for a lot
_$___ IN THE HOUSE OF REPRESENTATIVES of good conversations over the years between
these boys as the grow up in this commu-
Hononmo Lucy POPSON Wednesday, December 14, 2005 nity."
HON Mei M GRI ALVA Mr- DUNCAN- Mr Speaker- Or DQ°"'“b€'3 bit? QE?5i?$;‘;‘;?é$yt5*i?§tinii2;21"§§.£‘;i?5
' ' J Of this yean the Maryville f-hgh School. Red ment Dustin Lindsey said, that made all this
or Amzonp. Rebel football team finished its season with an oossibio
IN THE HOUSE OF REPRESENTATIVES UTld€f€‘6l€d l'€‘C0Vd of 15-0 35 ll b€C6m9 NW9 "It’s not only coaches and players, it”s peo-
Wednesday Decembm, 14 2005 2005 Class 4A State Champions. The Fled ple in genera1," he said. "We’ve got a won-
’ ’ _ Rebels defeated Melrose High School of dorful community thats booking us up, and
MT. Ml`. SPGBKGI`, I TISS before Memphis 23_·1O at this ygarrs championship p3Op]g§hg,1;]gvggg,gh Other-_"
YOU today t° recognize LUCY P°pS°"· or OL"' game in 'Murfreesboro TN. This victory gave The Commumby wasnyt cheering 'YhG.mgh°
Standin teacher in our Communit _ MrS_ . . ‘ . . of Nov. 29, 2003. Both teams were eliminated
9 V Maryville its second straight State champion- - - ·
p · th d moi iam f the Ariz n _ _ _ _ _ _ from the playoffs in semifinal losses.
TOPS?] fsf the $VoU A gf 2%O5 O a shlp, lis fifth championship ll'l lh9 past 6 YGEIVS Since then, neither team has lost to a
Egg 6[TO he Bil }_:NarY Or A ‘d h and its ninth Football Slate Championship team outside Blount County. Maryville went
9 Bac or O t G ear War ,OnOrS overall. undefeated and handed Alcoa its only two
*°a°*‘°'S that ale "°‘ °"'Y €X"'“F’}·"V "‘ the At the beginning er the 2005 season, Mary- losses Combined rooord= ow. .
classroom, but teachers that are involved in Ville Coach George Quarles Staiod that it was "I think that says about all you need to
the community as well. Nominated teachers his goal for oooh Senior Class to Win a State say about it," Quarles said. "There's good
are identified as leaders by parents students ·--· · foomll in Blom o°ImW-"
_ · _ _ · championship. This particular senior class has ··Iii this Size ei e county ~ Reid said om be
and cO`WOrkerS‘ Th€y_gam the aqmlratlon of not only achieved this goal set by Coach carrying around four state championship
everyone they work with, and their efforts on Quarles but they oxooodod it_ This group of boils is unboiiovobioy.
b6*l¤'* of ¤d¤°¤*'°" are "°l¤b'°- seniors will leave Maryville High sensei having Three years ooo Reid became A1¤oa~’S
d Iéucy lzopsoqrl excegds thesg criteria. She is Won three State Championships Completed coach, wondering if the Tornadoes would
e icate to er stu ents an to her commu- - ’ ovor win a game. Thoy’vo lost just six.
nity teaching at Walter Douglass Elementary each of its regular seasons undefeated and ..HoW lucky oem you gown Rom oskod
h· I f 23 d th. d d f th achieved an outstanding record of 58 wins to a,]0ud_ ~ SC 001 Or y9arS’ an Ir `gra B Or G only l defeat. The Red Ftebels became the "It seems so incredible that 365 days have
pasm y°arS‘ first team in 10 years to finish consecutive EMG by this f¤S¤·" Reid Said of lost Y€M"S
MVS- POF-lson _a|WaY$ makes §UV€ hor Stu' Seasons with an unbiemishgd record celebration. "It’s a tremendous amount of
dents SVG IGGITNHQ and she Stl`|VG${ to mHf$9 I am proud Of the Maryville Red Rebel fOOi_ WO1`k to QCD hE!I’G, and I Ehlllk Ch&l],S 0116 of
every student understand the material. She is ban program as it has booomo a poromial thlelthings that gets (overlooked ae times."
· t t ‘ ‘t l th' .
a teachgrthat “"o€`rSm"dS_th‘? d'ff€'Y°`m needs powerhouse under Coach Quarles. Year in Mer;-izivgaiiviéipiigb? buf; vim,
of S“'d9'“S· “’a°h'"9 mate"? '" "‘“"'p"".S*V'BS and year out, Coach Quarles has produced title ih 6 years. What was most fulfilling?
to ensure that no student is left out in the Winners on and ow tho football Hold- .tTho foot that 26 ioe of poopio didn.,] givo us
learning process. Mrs: Popsorl Slrlves to make ML Speaken I ask the readers Of me CON- much chance," Quarles said. "‘We lost so
her lessons fun and interesting. She is-proud GHESSIONAL RECORD and my fellow Colleagues many players from last years team, but
of her students and has a superior ability to io join me in Cengraiuleiing Head Coach those krds refused to listen to other people.
h I II h d h· . . They wanted to make sure that they gave
6 P 8 G" stu omg ec 'GVo· George Quarles and the Maryville High School -
When Mrs popson was asked about her _ _ _ themselves every opportunity to hopefully
_ · _ Red Rebel football team for their glorious vic- win e State Chempieiiehipy
TF€'{"9S upon rgcmpt °f the awaro She Stat°d· tory. I also include the following news article Thirty minutes after the ceremony,
Tm 'S Team §"°"h· ·f· T‘="’°:l'“9 'Sk'}°* °"° printed in the Knoxville News sentinel. The Quarles was fielding his lost ciuogstioo from
PBISO";. ls A ¤"° ° ,F’9°F’€ ‘”°' '"9 F°‘ reamsleadershap, strength, and determination reporters Ho wavod at e rassmg Moor
gether. She brought this statement to Ilfe Should bo rooognizod by an and their Spode where the crowd had stood, and offered one
when she dedicated her award to all those · · - ‘ lost pop talk to players of both toorosr
_ . , manshrp and dedlcatlon are at a level that tt » · I -
who help her in the Plowing Wells School Dis- - . H yfm VB Watched the m°v1? Friday
_ should be followed by €V6fy high SCf’lOOl {Gam Night Lights] you see people who live in the
mg'? h. . t I t th t f d in this country. past, where the greatest thing that ever hap-
Qac mg 'S a a or a GW POSSSSS an [From the Knoxville News Sentinel, Dec. 11, Donod to them was a state ohompiohshilw ho
even fewer choose to pursue as 8 career. All 2005) said. "I don’t want this to be the best thing
teachers in our community need to belrecog- MARYVILLE, ALCOA HONORED FOR STATE that ever happens to these kids. I want them
nized for their enormous efforts to enrich the CHAMPIONSHIPS to take what they ve learned in football and
lives of children. It is teachers such as Lucy (By Brad Gaskms) bemsgtccegsétguii iinéife. Oodh b d 1 d _
- - ea a,ag usan,a ea erin
Popson who geseryg awards for thaw dally MARYVILLE-—J0hI1 R€id and GBOFSB the community—all those things. Don’t let
"‘°h'€""`"‘€"t O h€"p'"g students . Quarles know good high school football pro- this be the high water mark. A lot or people
_ I honor LUCY Popson for hor gonofosm/· grams when they see ’em. Reid of Alcoa and live in the past, Thalys 3, mjSl;g_k€_**
kindness, and compassion and thank her for Qual-ics 05 Maryville both won Second QOH-
committing herself to the profession of leach- secutive state championships last weekend.
lng. Thoir programs Sharod tho Stego in oo1o— SPECIAL TRIBUTE TO DR. ROBERT
bration Saturday morning at the amphi- E_ FISCHELL
theater downtown, on what was proclaimed
PERSONAL EXPLANATIQN "Maryville Rebels and Alcoa Tornadoes
.L. Day" by the mayors of the respective cities. L'
M The respect between the Blount County OF MARYLAND
' C programs is more than mere chivalry. . IN THE HOUSE OF REPRESENTATIVES
OF WASHINGTON You think orA1coa-Maryvilleoyoii think Wednesday, December 14, 2005
IN THE HOUSE cp- REPRESENTATIVES of enemies, or rivals, Quarles said. And it _
W d d D b 14 2005 certainly wasn’t like that today. Both MV- CARDIN- MV- SDGBKBTI I VISG l0d&Y to
C nes ay’ ecem er ’ schools have a healthy amount of respect for ay Special tribute to Dr. Robert E. Flschell, a
p .
Mr. I\/IcDERMO`I'I'. Mr. Speaker, I was un- one another? _ _ _ mechanical engineer, biomedical engineer, in-
Hblé to bé lll W6Shl¤Ql0¤, DC, y6SlGrd6y, and ei um thou ‘§”·S€·’_’ RBI? Bald of MMYVIHR ventor, physicist, researcher and teacher.
part of today. As a result I missed several b§9°d §°‘*1$h“`*§ {AS b§°g‘gth°“é go d1’i1°“§;s Robert Fischell is one of the brightest, most
votes. Had I been able to vote I would have mgs ac. an or · O S 3* Snare 6 l` acccm lished cc Ie | have cvcr mc;
P P P
. cated to being good football teams. . . .
voted in support of H. Res. 487, S. 1047, H. Both orovod how good lose wookond in Let me tell you a little but about his career.
Res. 594, for the motion to recommit H.R. Muriieeebeie Meiyviiie been Memphis Mei- After graduating cum laude from Duke Univer-
3199, and a ainst final passa e of H.R. 3199. wsa 23-10 jn the Class 4A cme Emg In 2A sit in 1951 with a de ree in mechanical en i-
9 _ Q g , V _ 9 9
I would have voted against H.R. 3010. Alcoa beat Goodpasture 55-13. neerlng, Bob earned a Masters degree in

P E2532 Case I $98·eV·IEUNG§E§SION%@U IREGJOISSA- ExI:e0EP0¢Is10}';IégI)zQPks Pa%p:er9IIb0r 14, 2005
physics from the University of Maryland, CONGRATULATING WOMEN IN GOV- Staff Care nominating committee citing the
where he also holds an honorary Doctor of ERNMENT RELATIONS ON ITS physician‘s devotion to the town and its resi-
Science degree. BOTH ANNIVERSARY dents. She has an average patient caseload
In 1959, he went to work for the Johns Hop- —-— per week of 250, a successful practice of
kins Applied Physics Lab (APL), where he de- HON DEBORAH PRYCE 5,000 patients and works an average of 80
veloped a number of inventions dealing with OF OHIO hours per week. The nationally renowned
the control of satellites. His work at APL has "Country Doctor of the Year" award includes
led tc nurnercus awards, including thc IR—100 IN THE HOUSE OF REPRESENTATIVES a signature plaque that features an illustration
Award which is presented annually for the 100 Wedneeddyr Deeembef 14. 2005 of a physician making his rounds by horse and
most significant inventions. He has won this Ms PRYCE or Onio_ Mn Speaker. i rise. buggy. In addition, Dr. Poe will be provided
honor tvil Deeeme ell ei) egein in Ore Ie9·i'ee a staple of empowerment for Washington, C args.
satellite. D_C_ Wo n who so s ih the f`9|d of o om- Dr. Poe has received numerous awards and
Dr. Fischell holds nearly 200 U.S. and inter- mehi Iei;IE,hs_ N I g V recognition which include being named Busi-
national patents. His inventions—which in- This yea, is Ihs goth ahhiVsIsaIy of Womsh ness and Professional Womanof the Year,
clude an implantable insulin pump, a re- ih Govemmshi Hsisiiohs WGH is s hon- Winona Times; Family Medicine Assistant
chargeable. pacemaker, a flexible stent- for psi-Iissh organization that educates shd sd- Chief Resident, University of Mississippi Med-
placement ln coronary arteries, and a micro- Vahoss Women ih ihis fieid_ WGH helps ical Center; CIBA-Gelgy Community Sewtce
mInIE.tUTIZBd COmpUIGr Can bG implanted Women be Smarter, Stronger, and more Inf|u- AWOIQI UIIIVGIISIIIY of SCh00I
to revent epileptic seizures—have changed · · Medicine and; Cultural Diversity Academic
th P t_ f d_ _ O d h d d entlal ln the work they do. A h_ TA d
e prac ice o me lclne an save un re s S · · i _ th I- ld I I i . c levemen war .
aris zi .. U » -., . M 'I¥'I?iI·I I? W¤“TI°"I'"I??I VIII C.:?.i.,i.O%..2.ri*:;;¤ 23.;*.2: iI.*I;i;2:::
TI SCGITI Gl' , G IIIVGFSI O ary- f d d i b i 30 h , Q
land at College Park is announcing the estab- xgihezuxleie gpusoogiihouto heyzghi {:9; xsi; and professional respect of Iher community,
9
Iishment of the Fischell Department of Bio- domineied fieid_ patients and colleagues and IS worthy of this
engineering and the Robert E. Fischell lnsti- i honor WGH today oeoeuse h provides auspicious award. I commend Dr. Poe, the
tute for Biomedical Devices. eduoeiiohei ehd networking oooohuhities for "Country Doctor of the Year" and wish her
' wee my. °°"9¤9N€S in the 0-S; H°¤S° 0* its members and me community. These ¤<>¤Ii¤¤¤¤ sucsess
Eepggsinwltlves IO I°mtI“€ 2 h°0°"00 R°b60 women serve our country by representing pub- ——————
wit. 'SILS ’m2EB'"22E?.l¥§.. "222$fl‘Sull2I2"‘?é ic imsl .¤*¤~¤S= terra'- sists anti I°°aI HT- 42% THE TAX RELIEF
. . . . _ QOVGTHTTTGIWI, COTQOTEIIOHS, If3d6 HSSOCIEIIODS,
medicine, space discovery and higher edu and many oihers
°a0°n· I am proud to say that I join many of my col- spaaou OF
CO OTT VI S LZ2?.§’§§. £‘Fl$e‘B ?32§'$§i..Zi.u%"tIé'Ql°;Z'I NON- DENNIS NOONE
MMEM ATIN THE JA T - · _ _ _ _ _ os KANSAS
WAGNER OIDAY PROGRAM encourage the organization to continue its im- IN THE HOUSE OF REPRESENTATIVES
L portant mission of advancing and empowering Thursday Decembw 8 2005
WOHIBR. r I
HON` `Ol;El;O§;l§AGST0N Congratulations to WGR for its service to Mr. MOORE of Kansas. Mr. Speaker, I rise
IN THE HOUSE OF REPT 3.“J.§‘?L%?S’?é L*2,°..‘;“‘ 3° Nm i""’ ‘°' ""IN Ii.’2at¥YE§’5i§'i'?§§O.E2I.r§i§§SQ%IF“ ‘° HN 4297*
W€d”€$d0·y» D€00m0€T Mr 2005 I I do not oppose tax cuts and in a more sta-
1
Mr. KINGSTON. Mr. Speaker, I wish to ble fiscal climate I could support reduced tax
commemorate the Javits-Wagner O’Day pro- HONORING DR- KATRINA POE rates for capital gains and dividend income.
gram (JWOD) on the service they provide to TT' What I do oppose is borrowing money to pay
thousands of individuals. HON. BENNIE G. THOMPSON for tax cuts, and particularly for tax cuts that
The JWOD program is the single largest OF MISSISSIPPI do not expire for another three years.
source of employmentrfor individuais who are IN THE HOUSE OE REPRESENTATIVES In 2001, I was one of only 28 House Demo-
bllnd or have severe disabilities. This program W d d D b 14 2005 crats to vote for President’s Bush’s 2001 tax
employs more than 45,000 people. The JWOD 6 nes ay· €C0m_ ET _· cuts that reduced marginal income tax rates.
program trains persons with disabilities to ac- MI. THOMPSON cf MISSISSIPPI. MI- SPSSK- Since 2001, however, our country’s fiscal con-
quire job skills that will be resourceful in their ef. I WOIIICI III everyday lives. With these skills and training, I·3mIIy DIIYSICIBII. DI'- KHIIIII8 POS. _ 2001, the Congressional Budget Office (CBO)
a participant in this program can receive OI- KHIIIIIH Pee. 35. IS being Iee0QIIIZeCI by predicted that the 10-year budget surplus
wages and benefits thereby gaining a greater SIHII Cafe I¤C0_IP0I3Ied. 60 IIISUIe¤ee C0ITI· would be $5.6 trillion. That projected 10-year
independehce and quaIity_of life. _ P¤I`Iy_ IIISI PIGIIICISS Sb0IT·IeIIII COI/eiege Id surplus of $5.6 trillion has deteriorated into a
In my district ln Georgia, there is a JWOD physicians as Country Doctor of the"Year. prgjgctgd $3_9 iyiiiion ooiioii during ino Saino
program named Happy Hour that exemplifies This national honor IS awarded to a doctor poIioo_ In FYQOO5, {ho FoooIai Govoynnqont
the good work that this organization is built who has dedicated his or her life career to ran a budget ooiioii or $319 oi|iion_ ino Iniyo
upon. Happy Hour employs 170 disabled indi- sewing rural communities. Dr. Poe, a famiiy lergeei deficit in our Netienle history, l
vlduals and gives them an opportunity to con- physician at the Greenwood Leflore Hospitals Funher, on February 17, 2004, the national
tribute to their communities. Executive Director Kilmichael Clinic, also sewes as chief of staff debt of the United States exceeded $7 trillion
SteveBSgtii/to lgndkComr;rjtunity fReIatic;n;0Ma(hO at éhe Kilritiehael hcospitgl. P T f gritlge fig; tigtoeogn odur countwisdhistore. On
ager o I an s ea an o ice o -1 lnce I gra e, r. oe, a naive 0 co er , , t e nationa e t o te
hard working staffers along with many volun- Kilmichael, Mississippi wanted to become a United States exceeded $8 trillion for the first
teers who are all dedicated to ensuring each physician. She graduated from Kilmichael High time in our country's history. That is an in-
person reaches a common goal. School in 1988 and went on to earn a bach- crease of $1 trillion in our national debt over
Happy Hour has a working relationship with eIor’s degree in biology from Mississippi State the last 2 years. It took our country 193 years,
Robins Air Force Base. Through this relation- University in 1992. Dr. Poe attended medical from 1787 to 1980, to rack up $1 trillion in
ship Happy Hour participants are able to help school at the University Medical Center in debt, and just under two years, from 2004-
the government and save taxpayers money. A Jackson, MS. Only two months after com- 2005, to match that level of borrowing.
few of the projects that help Robins Air Force pleting her residency training at UMC in June An $8 trillion national debt comes down to
Base is Robin's Recycling, respiratory clean- 2001, she began officially sewing the people nearly $27,000 per person in our country, and
ing and repair, tool die numbering, and aircraft of Kilmichael where she spent several sum- that is simply unacceptable. The first rule of
sorting. Though they may seem minor, without mers assisting Dr. L.C. Henison. holes is that when you’re in a hole and you
Happy Hour, workers who do these tasks at Dr. Poe, who was nominated by Nurse don‘t want to go deeper, stop digging. It is
Robins AFB would have a much harder time Linda Turner of the Kilmichael Clinic collected now past time that we stop digging our coun-
operating. and submitted testimonials from patients to the try deeper and deeper into debt, leaving our