Free Motion to Amend/Correct - District Court of Delaware - Delaware


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Date: September 1, 2005
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State: Delaware
Category: District Court of Delaware
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E ri Case 1 :04-cv-01419-JJF Document 24 Filed 09/01 /2005 Page 1 of 4
In the United States District Court
N For The District Of Delaware
CATHY D. BROOKS-McCOLLUM, Civil Action No. 04-1419
& Emerald Ridge Service Corporation
115 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694
Plaintiff(s)
vs. JURY TRIAL DEMANDED
State Of Delaware
Delaware Chancery Court
Chancery Court &
Vice Chancellor Donald Parsons
(Individually and in his official capacity as
Justice of the Chancery Court of New Castle County Delaware) F [ L E D
New Castle County Courthouse
500 North King Street p _
Suite 11400 ‘ l
Wilmington, DE 19801
Defendants U.$_ 9 ** ‘
U [ S l m '? gil lil;
MOTION TO CORRECT
Prior to the Appeal being tiled against the following Defendants Plaintiff Cathy D. Brooks-McCollurn
hereby requests that the US District Court correct the courts error in docketing the Appeal, as the appeal was
tiled as shown in Exhibits A and B and the record should reflect this properly. Pursuant Fed.R.Civ.P Rule 60.
The error of the court docketing the case incorrectly is not a harmless error as Fed.R.Civ.P Rule 61 would
provide, instead this error carries over to District Court action 04—0419(JJF), where State Farm is claiming they
have represented Emerald Ridge and 04-0703(JJF) where there are not any valid Directors improperly utilizing
Corporation funds., when none of the parties in those pleadings were valid Directors or confirmed by any other
court, as Plaintiff was in the Delaware Supreme Court. Whereby, Plaintiff should be allowed to reargue her
pleading being corrected pursuant Delaware Rules Of Civil Procedure 7.1.5 and pursuant Fed.R.Civ.P Rule 60.
The error made by the courts docketing is substantial and would hurt both Emerald Ridge Service Corporation
and Plaintiff Brooks-McCollum. lt is clear by the iilings and by the Complaint that these proceedings were
tiled in this Court for Cathy Brooks-McCollurn and Emerald Ridge Service Corporation.

\ - ·
Cathy D. rod s-McCollum (Pro Se)
115 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694

In the United States District Court
For The District Of Delaware
CATHY D. BROOKS-McCOLLUM, Civil Action No. 04-1419
& Emerald Ridge Service Corporation
115 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694
Plaintiff(s)
vs. JURY TRIAL DEMANDED
State Of Delaware
Delaware Chancery Court
Chancery Court &
Vice Chancellor Donald Parsons
(Individually and in his official capacity as
Justice of the Chancery Court of New Castle County Delaware)
New Castle County Courthouse
500 North King Street
Suite 11400
Wilmington, DE 19801
Defendants
CERTIFICATE OF SERVICE
I Cathy D. Brooks-McCollum hereby certify that on this 31st day of August 2004, I caused to be served
a true and correct copy of the foregoing Complaint regular postage mail, postage prepaid, upon Gregg E.
Wilson, 1.D. #85, Stephani J. Ballard, I.D. #3481, Deputy Attorneys General, Carvel State Office Building
820 North French Street, Wilmington, De 19801, (302) 577-8400.
Chg DM; r 9
Cathy D. rooks-McCollum (Pro Se)
115 Emerald Ridge Drive
Bear, DE 19701
(302) 832-2694

Case 1:04-cv-01419-JJF Document 24 Filed O9/O1/2005 Page 4 of 4
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