Free Letter - District Court of Delaware - Delaware

- Case 1:94-cv-00336-KAJ Document 453-2 Filed 03/24/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BY HAND DELIVERED Dated: March 17,2005
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MR. Joan w. SHAW,ESQUIRE
YOUNG, CONAWAY,STARGATT & TAYLOR,LLP R; `@%%Q
LAW OFFICES x- &g@g
THE BRANDYWINE BUILDING 52 :§%%"
1000 WEST STREET, 17TH FLOOR. _ ~* pg;
WILMINGTON,DELAWARE.19801 Q? §%§
(L-G . . 1
Re: Hamilton v. Leavy, et al.
Civil Action No.94—336—KAJ*
Dear Mr. Shaw,Esquire:
Delaware Lawyers Rules of Professional Conduct, Rule 1.15.
permits a lawyers to cease representation where "good cause for withdra-
—l exists". Mr. Shaw,Esquire, on March 17,2005 when Judge Jordan, rule -
or ruling by denying jury to examine a document concerning the plaintiff
/appe11ant, evidence was (Deposition Exhibit-Martino/2/and/3). Plaintiff
/Appe1lant, believe he has appeal grounds abuse of discretion by refusi-
-ng the jury to see evidence that are record like (Deposition Exhibit--
-Martino/2/and/3).
1. Mr. Shaw,Esquire, why you didn't objection on record -
preserving my right on appeal on that issue, where Judge Jordan told the
instruction by telling the jurys my trial on Mrach 17,2005 they could -
not see document in evidence which was. (Deposition Exhibit-Martino/2 -
and item 3). Also Mr. Shaw,Esquire, the evidence which part of plaintiff
case that the requesting to see where or was (Deposition George Mart-
-ino /taken pursuant to notice at the offices of Young Conaway Stargatt-
& Taylor, LLP, The Brandywine Building, 17th Floor, 1000 West Street, -
Wilmington, Delaware, beginning at 2:00 p.m. on Monday, November 3,2003,
before Ann M. Calligan, Registered Merit Reporter and Notary Public.).
2. Plaintiff/Appellant Jerome Hamilton, Pro Se, will being
raised in higher court why my attorney Mr. Shaw, produce for the jurys -
in my trial on March 17,2005, The jury wanted examine date of the reprim-
-and against Correctional Office Simpson, was on June 15,1992 about they —
calling plaintiff a snitch. Mr. Shaw,Esquire, i need to ask you this ques-
—tion why you didn't tell the court on plaintiff/appellant behalf where t-
-he document was in plaintiff evidence and exhibit's in record which was -
crucial facts should have been granted by court. Mr. Shaw,Esquire, why th-
-eir is knew objections on record for high court review that their was cl-
-ear1y above and abuse of discretion by Judge Jordan on March 17,2005 bec-
—ause i had a jury trial not a judge trial .......
1.

· Case1:94—cv-00336-KAJ Document 453-2 Filed 03/24/2005 Page2of2
3. Plaintiff/Appellant Jerome Hamilton, Pro Se, is making
this record for future reference that Judge Jordan, deny the members of jury
request the date of the reprimand where Correctional Official Simpson who -
call plaintiff a snitch. See:(Deposition Exhibit-Martino/2 and 3). And this
document is part of the record exhibits at trial on March 17,2005. Plaintiff
question is why members of the jurys given this exhibits documents that was
or should have been a part of plaintiff evidence at trial to support my case
by preponderance of the evidence would show defendant‘s did violated plaint·
-iff constitutional rights. Mr. Shaw, did you object on plaintiff behalf th-
—at Judge Jordan, abuse their discretion by denying members of jurys their —
duties.
4. Plaintiff/Appellant/Jerome Hamilton, Pro Se, believe —
because it is all ready on the record that you Mr. Shaw,Esquire, are in viol-
-ation of (Delaware Lawyers Rules of Professional Conduct, Rule(l.)(16.) Pe-
—rmits a lawyers to cease representation where good cause have been show a»
-gainst Mr. Shaw,Esquire, misconduct by given plaintiff bad advise and stra-
—tegy when you you was managing above—captioned case. And Plaintiff, think -
that is another good cause reason for your withdrawal from this case if it —
a issue you will try to argue with whoever.
5. Mr. Shaw,Esquire, could you please explain for record
why it was so many side bars discussion with you the judge and defendant's
attorneys that plaintiff and members of jurys could hear. Also Mr.Shaw,Esqu·
-ire, did Judge Jordan, did deny any of plaintiff evidence not to come into
evidences for members of jurys consideration at jury trial on March 17,2005.
If so Mr.Shaw,Esquire, please explain did you raised any objections to any —
side bars discussion to preserved plaintiff appeal issue's rights in above—
captioned case. For the record jury trial started on March 14, thru 17,2005.
Mr. John W. Shaw,Esquire, please response to this letter
document and give me your side of the story, and what you think happen on —
March l4,thru 17,2005 jury trial .....
DBM?-·0= March 17-2005 Respectfull suggitted Hi
&1Hb1f§?E%@E an€$§g&ome agaltdh
CC_ Pro Se,
‘ _ _ _ 320 East Fifth Street/Apt.#609 ‘
Plalntlff/Hamllton Wilmington,Delaware.19801
Clerk of the Court
Mr. Peter T. Dalleo ‘
sworn to and Subscribed before me. thiS,.. "GHV
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