Free Motion for Permanent Injunction - District Court of Delaware - Delaware

— Case 1 :05-cv-00031-SLR Document 8 Filed O3/28/2005 Page 1 of 3
UNITED STATES’ DISTRICT COURT
DISTRICT OF DELAWARE
CIVIL ACTION NUMBER:
) 05-003 I-SLR
AZUBUKO - ) Q
Plaintiff )
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EASTERN BANK - ) .g p
Defendant ) :-7 “ i
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PLAINTIFF’S MOTION FOR COURT TO ISSUE EMERGENCY PERMANENT l
INJUNCTION/WRIT OF MANDAMUS FOR DEFENDANT’S RETURN OF THE CAR I
IT REPOSSESSED
These would be the bases for the head:
0l) The Plaintiff had submitted ‘Plaintiff Emergency Motion for the
Defendant to Return the Car’ pending with the Court dated March 17th — 2005. The
Plaintiff deemed it intelligent to submit current motion for four reasons, namely:
a) The receipt of the Court’s ruling and the propensity for over-protection of
the Defendant;
b) Non-mentioning of an injunction in the pending motion;
c) The demand by the Defendant’s Agent for the Plaintiff to give up the key
to the car to the Defendant’s Agent cunningly and
d) Agent’s reiteration for auctioning the car sooner.
02) The Court should grant the Plaintiff the motion, so as to prevent the
auction of the car sooner. If it were auctioned, it would complicate issues before the
Court. Well, anything could be quantified in dollars value!
03) The Plaintiff needed not to make the motion based on sub judice [as
already particularized upon and exhibited] However, the Plaintiff had to make the
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— Case 1:05-cv—OOO31—SLFl Document 8 Filed O3/28/2005 Page 2 of 3
motion, because the Defendant’s employees the Plaintiff spoke with acted as if they
understood the law, but in all modesty, they did not.
04) Hopefully, the Court should handle the case cautiously and if it became a
legal impossibility, the Plaintiff would appeal it immediately. Nonetheless, if the Court
failed to grant the Plaintiff the motion in question, it would be akin to "state action"
discrimination. It would trigger ofthe Court and the Defendant being jointly or divisibly
liable to the Plaintiff For the Court, it qualified for "failure to enforce law" amongst
others. [42 USC Sections 1986, 1983 and l985(3)] The Court entered judgement in
favor of the Defendant for lack of personal jurisdiction, but the Plaintiff had meticulously
disabused the stance and hoped the verdict would be reversed. If it were not reversed, it
would typify knowingly violation of the law or exposure or condemnation of the Plaintiff
to injury of law. Indeed, even Pharaoh would change his mind central to the Plaintiff s
mot.ion or particularization upon the bases, which justified the Court’s exercise of in
persomzm or general jurisdiciiorz over the case or the Defendant. The invaluability of the
Clayton Act or the anti—trust law the Plaintiff specified in the Complaint and in the
current motion would not be over-emphasized.
CONCLUSION
With candor in communications and in the name of natural justice, the Plaintiff
was not crying for any judicial moon. The Court should unhesitating grant the Plaintiffs
prayer or motion. The car should be preserved or return to the Plaintiff: if the Court
deemed its preservation to be a legal impossibility, the Court was entitled for its
thinkings, but the Plaintiffwould remind the Court that "ifit kissed, it has to man·y." In
essence, theoretically, the law should be no respectcr of any person. The Court had no
discretion to grant the motion, but duty to act. It never meant that the Plaintiff presumed
upon the generosity of the Court. The interest of the law should be maximized if it could
not be optimized. "Ifthe Court listened, it would hear the voice ofthe Plaintiff"
[Proverb]
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- Case 1:05-cv—OOO31—SLF1 Document 8 Filed O3/28/2005 Page 3 of 3
Respectfully submitted from Boston — Massachusetts — on Friday e March 25"` — 2005.
CHUK ‘· `‘ I i
Pro Se,
P. O. Box 1351,
Boston — MA 02117-1351.
Telephone: (617) 265 6291.
CERTIFICATE OF SERVICE
Under the penalties for perjury, the Plaintiff certified that the true copy of the
head was served upon the Defendant and the Attorney General of the United States at
their respective address on Saturday — March 26th — 2005 - thus:
Eastem Bank,
One Eastem Place,
Lynn, Massachusetts 01901-1508 and
United States’ Attomey General,
Department of Justice
Room 5614,
950 Pennsylvania Avenue, N. W.,
Washington, DC 20530-0001.
CHUKWUEA E. AZUBUKO,
Pro Se.
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