Free Motion for Reconsideration - District Court of Delaware - Delaware

Case 1 :05—cv—00047-GIVIS Document 39 Filed 04/26/2006 Page 1 of 3
1 _ CL 1 _
Qjgemz- L%1¤@L7ec226ad!
3 009 Delaware Street
Mt1i·shalr`oi1·, DE l 08—5 709
Phone {/.31U.?,] 603- 9242
(Yell (302)
1...1..1..1....1......1..1. 551.%%%lit?.-Qéidnzi-.e€<2r2¢ 1..1.,11,.1..1..1..1.,1,.1..
April 16, 2006
A1 " 11 1 1 1 1]1.Q11 111/ 11 10 1111
Judge Gregoijv M Sleet ZBHJET4
United States District Court .........,.c.,,.. 1..t1
· . .D¥S1l1ZQ'“ 1 '`1‘ O HT
444 N Kmg S"”44‘ ,t.,.t 1. ttit . 1 ttt, s 1
Wilmington, DE ]980]—3570 " '‘4‘
Re: Brian K Reinhold vs. NALC ]9] & USPS
US District Court Case # 05-047 (GMS)
Dear Judge Sleet:
Please find enclosed my request for you to reconsider your order dated
April ] 0, 2006 and reopen the case and schedule it jiur a_ jury trial.
_ Sincerely,
ii.; V _,
Brian K Reinbold
Hand delivered to court
Cc:
Sent via certyied mail # 7004 I ] 60 0006 3] 04 l l 6] w/ return receipt T 0
Oriana Vigliotti c/o Cohen, Weiss & Simon LLP
Sent via certfied mail #7004 ] ] 60 0006 3] 04 ]260 vv/return receipt
Patricia Hannigan US Attorney General
jile

Case 1:05—cv—00047-G|\/IS Document 39 Filed 04/26/2006 Page 2 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF 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: C
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 was received by them on July 28, 2005.
On July 26, 2005 I the plaintiff sent a copy of my response to attorney for USPS for
the Request for Interrogatories and Documents dated June 29, 2005 by NALC 1977
& NALC 191 and was received by them on July 29, 2005.
On September 6, 2005 I the plaintiff sent a copy of my requests for Interrogatories
and Documents dated September 5, 2005 to attorney for USPS and was received by
them on September 8, 2005.
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 September 8, 2005.
I still have not received a response from either defendants for my request for
Interrogatories and Documents.

Case 1:05—cv—00047-G|\/IS Document 39 Filed 04/26/2006 Page 3 of 3
The last correspondents I received from the attorneys for NALC 1977 & NALC 191
Was there Motion to Dismiss for Failure to Answer there Interrogatories and
Documents Request.
The last correspondents I received from the attorneys for USPS
was there Documents for Disclosure.
I have never received a Motion to Dismiss from the USPS.
The USPS has filed documents stating that the NALC 191 had not filed statements
to the Step B Team in my support for or against me in my grievance.
The USPS has filed documents stating that the NALC 191 knew and believed that
the USPS was harassing me and nothing was done.
The USPS has filed documents stating that I violated the SOP and then contends I
followed it at the same time.
CLOSING:
I believe the records and documents filed by USPS show that the NALC 191 &
USPS were in violation of the CBA and there own agreements and disregarded any
rules or guidelines so they could remove me from the post office.
I ask that the court reconsider the order filed on April 10, 2006
And reopen the case and schedule for a jury trial at it’s earliest time or schedule a
conference were the claims can be proven.
Brian K Reinbold
3909 Delaware Street
Wilmington, DE 19808-5709