Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1 :04-cv-01534-KAJ Document 27 Filed 09/15/2005 Page 1 of 1
TN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OE DELAWARE
MARTIN DURANT, :
Plaintiff, C.A. NO. 04-I 534 (KAJ)
v.
2 J URY TRIAL DEMANDED
PERFECT CARE NURSES, INC., :
Defendant.
PLA1NT`{FF’S RESPONSE TO DEFENDANTS
MOTION FOR PARTIAL SUMMARY JUDGMENT
NOW COMES, Plaintiff, Martin Durant, by and through his counsel, and responds to
Def endant’s Motion for Partial Summary Judgment as follows:
l. Plaintiff does not oppose Defendant’s motion for partial summary judgment.
2. Plaintiff does oppose Def endant’s request for an award of all costs, expenses and
any other relief that the Court deems appropriate. This matter could have been resolved by and
between the parties without the Court’s intervention, however the Defendant did not eontaet
Plaintiff prior to the filing of this motion. Therefore, Plaintiff respectfully requests that the Court
not award Defendant costs, expenses and any other relief regarding this instant motion for partial
summary judgment.
MARGOLIS EDELSTEIN
Jeffrey K. Martin, Esq_uire (#2407)
Keri L. Morris, Esquire (#465 6)
l509 Gilpin Avenue
Wilmington, Delaware 19806
(302) 777-4680 phone
(3 02) 777-4682 facsimile
iniartiiigdlniaiiigolisedelstein.oom
lonorrisgegniargolisedelsteineom
Attorneys for Plaintiff
Dated: September I5, 2005

Case 1 :04-cv-01534-KAJ Document 27 Filed 09/15/2005 Page 1 of 1
TN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OE DELAWARE
MARTIN DURANT, :
Plaintiff, C.A. NO. 04-I 534 (KAJ)
v.
2 J URY TRIAL DEMANDED
PERFECT CARE NURSES, INC., :
Defendant.
PLA1NT`{FFâS RESPONSE TO DEFENDANTS
MOTION FOR PARTIAL SUMMARY JUDGMENT
NOW COMES, Plaintiff, Martin Durant, by and through his counsel, and responds to
Def endantâs Motion for Partial Summary Judgment as follows:
l. Plaintiff does not oppose Defendantâs motion for partial summary judgment.
2. Plaintiff does oppose Def endantâs request for an award of all costs, expenses and
any other relief that the Court deems appropriate. This matter could have been resolved by and
between the parties without the Courtâs intervention, however the Defendant did not eontaet
Plaintiff prior to the filing of this motion. Therefore, Plaintiff respectfully requests that the Court
not award Defendant costs, expenses and any other relief regarding this instant motion for partial
summary judgment.
MARGOLIS EDELSTEIN
Jeffrey K. Martin, Esq_uire (#2407)
Keri L. Morris, Esquire (#465 6)
l509 Gilpin Avenue
Wilmington, Delaware 19806
(302) 777-4680 phone
(3 02) 777-4682 facsimile
iniartiiigdlniaiiigolisedelstein.oom
lonorrisgegniargolisedelsteineom
Attorneys for Plaintiff
Dated: September I5, 2005

Case 1:04-cv-01534-KAJ

Document 27

Filed 09/15/2005

Page 1 of 1