Free Motion for Reconsideration - District Court of Delaware - Delaware

Case 1 :O5—cv—OOO47-GIVIS Document 43 Filed 05/O2/2006 Page 1 of 3
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1 Judge Gregorjytli Sleet § J
United States District Court .-.- s" [6; 1 1
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844 N. King Street go SM"'
Wilmington, DE 19801-35 70 U1 1
Re: Brian K Reinhold vs. PMLC 191 & USPS
US District Court Case # 05-04 7 (GMS)
Dear Judge S leet:
Piea.se_;‘inci enclosed my requestfor you to reconsider your order datecl
April 10, 2006 and reopen the case and schedule it for a juijy trial,
` Sincerely,
A‘—_·,.`L2é;;r§ ;;“—;—~__-T::“’.,i_y_n_
Brian KRetn12ola` "" `
Hand delivered to court
Cc; U
Sent via certified mail # 7004 1160 0006 3104 1161 wf return receipt T o
Oriana Vigiiotti c/o Cohen, Weiss & Simon LLP
Sent via certified mail ii?004 1150 0006 3104 1260 usrreturn receipt
Patricia Hannigan US Attorney Genera}
file

I Case 1 :O5—cv—OOO47-GIVIS Document 43 Filed 05/O2/2006 Page -2 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OE DELAWARE
BRIAN K REINBOLD ‘
Plaintiff, ` .
vs. ` Civil Action Number
05-047 GMS .
NALC BRANCH 191 & USPS -
Defendant ·
MOTION FOR RECONSIDER ORDER - ‘
AND SCHEDULE FOR JURY TRIAL
On April 10, 2006 the court ruled on a Motion for Summary Judgment filed by the
USPS, in it’s order the court states that I the plaintiff never responded to the motion
filed by the USPS and have not submitted any arguments to support my claims
when I filed the case. The NALC filed a Motion to Dismiss for Failure for Lack of
Prosecution which the court denied.
Arguments in Support:
On July 26, 2005 I the plaintiff sent a response to attorneys for NALC 1977 &
NALC 191 for there Request for Interrogatories and Documents dated June 29,
2005 and iyas received by t nn on J ly 28, 200 .
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On July 26, 2005 I the plaintiff sent a copy of my response to attorney or USPS for
the Request for interrogatories and Documents dated June 29, 2005 by NALC 1977
& NALC 191 and was received by them on Jul *29, 200 . ____ ‘
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Ou September 6, 2005 I the plaintiff sent a copy of my req ests for ntrrogatories
and Documents dated September 5, 2005 to attorney for USPS and was received by
there an Septembe 8, 200 .
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. On September 6, 2005 I the plaintiff sent a copy of my requests for Interrogatories
and Documents dated September 5., 2005 to attorney for NALC 1977 & NALC 191
and was received by them on Se tember S, 2005.
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I still have not received a response from either defendants for my request for
I interrogatories and Documents.
I
I
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The last correspondents l received from the attorneys i`orlNALC 1977 & NALC 191 _
Was there Motion to Dismiss for Failure to Answer there Interrogatories and
Documents Request. _ r -
The last correspondents I received from the attorneys for USPS
was there Documents for Disclosure.
l have never received a Motion to Dismiss from the USl’S.
The USPS has tiled documents stating that the NALC 191 had not filed statements
to the Step B Team in my support for or a ainst me in my grievance gg
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The USPS has iiled documents stating that the NALC 191 cuew and believed t at
the USPS was harassing me and nothing was done. _
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The USPS has tiled documents stating that I violated the SOP and then contends 1
followed it at the same tziye.
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CLOSING: _
l believe the records and documents filed by USPS show that the NALC 191 &‘ , '
USPS were in violation of the CBA and ther own agreements and disregarded any
rules or guidelines so they could remove me from the post office. -
I ask th at the court reconsider the order filed on April 10, 2006 A
And reopen the case and schedule for a jury trial at it’s earliest time or schedule a 9
conference were the claims can be proven.
Brian K Reinhold _
3909 Delaware Street
Wilmington, DE 19808-5709