Free Motion to Appoint Guardian/Attorney ad Litem - District Court of Delaware - Delaware

Case 1 :08-cv—00369-GIVIS Document 3 Filed 06/19/2008 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DEBBIE NELSON §
Guardian ad Litem for KN I §
§ §
§
Plaintiffs, §
§
v. §
§ C. A. No.
DANIEL WILSON, individually, and as § O 8 `° 3 6 9 as
agent employee of the State of Delaware, §
and STATE OF DELAWARE §
DEPARTMENT OF SERVICES FOR § Jg Tdal Demandg
CHILDREN, YOUTH, AND THEIR § ’
FAMILIES, DIVISION OF YOUTH §
REHABILITATIVE SERVICES, §
§
Defendants, §
PETITION FOR APPOINTMENT OF GUARDIAN AD LIIEM
1. Plaintiff, Debbie Nelson, have a cause of action on behalf of the
pl&iHtiff,&, in the above-captioned action.
2. Plaintiff, Debbie Nelson, requests the Court to appoint Plaintiff`,
Debbie Nelson, as Guardians Ad Litem for the Plaintiff,
3. The Affidavit of Leo J. Boyle is attached hereto.
DEBBIE NEI?|N
, n Z V.
LEO J. B0 E, ESQU
5197 W. W dmill Drive, Suite 26
Woodmill Corporate Center
Wilmington, DE 19808
(302) 994-1300
Attorney for Plaintiffs
Dated: June 3, 2008
Wp5l/clients/Nelson /Petiton for Guardian Ad Litcm

Case 1 :08-cv-00369-GI\/IS Document 3-2 Filed 06/19/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DEBBIE NELSON §
Guardian ad Litem for KN, §
§
Plaintiffs, §
§
v. §
§ C. A. No.
DANIEL WILSON, individually, and as §
agent employee of the State of Delaware, §
and STATE OF DELAWARE §
DEPARTMENT OF SERVICES FOR § Jury Trial Demandexi
CHILDREN, YOUTH, AND THEIR §
FAMILIES, DIVISION OF YOUTH §
REHABILITATIVE SERVICES, §
§
Defendants. §
AFFIDAVIT
STATE OF DELAWARE )
) SS.
COUNTY OF NEW CASTLE )
I, Leo J. Boyle, counsel for the Plaintiffs in the above-captioned matter, being
duly sworn, deposes and states that:
1. I have or will immediately file an action in this Cum on behalf of
the Plaintiffs against the above—named Defendant for injuries sustained by Plaintiff, KN, in
a personal injury matter that occurred on July 7, 2007. Plaintiff was assaulted by an
employee of the Stevenson House in Milford, Delaware.
2. Plaintiff, Debbie Nelson is the mother of Plaintiff ICN, a minor, and
is the likely persons to act as Guardians Ad Litem for Plaintiff, KN.
3. I request the Court to enter an Order appointing Plaintiff, Debbie
Nelson, as Guardians Ad Litem for Plaintiff, KN to pursue the above-capt;<:ned action.

_ V Case 1:08-cv-00369-GI\/IS Document 3-2 Filed 06/19/2008 Page 2 of 2
LE J. no ..2 n.w2,+)
5197 W. W dmill Dave, Suite 26
Woodmill Corporate Center
Wilmington, DE 198-33
(302) 994-1300
Attorney for Plaintiffs
Date: I —.
SWORN TO, SUBSCRIBED AND ACKNOWLEDGEH beforezrriei a. I
Notary Public, for the State and County aforesaid, this / Z day of · _ ` ,2008. ·”
" I /
i ¤ ·
n TARY UBLIC /
1 nvm L smmnm
_¤¤v Public- state of DQUIQ
§ . EXH188 March MQ]
Wp5 I/clientsNels0n/Petition for Guardian Ad Litem

Case 1:08-cv-00369-GI\/IS Document 3-3 Filed 06/19/2008 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DEBBIE NELSON § T
Guardian ad Litem for KN, §
§ r
Plaintiffs, §
§
V- § .
§ NO. ;
DANIEL WILSON, individually, and as §
agent employee of the State of Delaware, §
and STATE OF DELAWARE §
DEPARTMENT OF SERVICES FOR § J Trial Demandi
CHILDREN, YOUTH, AND THEIR § V
FAMILIES, DIVISION OF YOUTH § i
REHABILITATIVE SERVICES, §
§ i
Defendants. §
011111111
NOW, TO-WIT, this day of , 2008 on
reading the attached Petition for Appointment of Guardian Ad Litem, it ereby Ordered I
that Plaintiff, Debbie Nelson, is appointed as Guardians Ad Litem for 'ntiftQ KN, for
the purpose of bringing the above-stated action.
I I .
Wp5l/clients/Nelson /Petition for Guardian Ad Litem

Case 1:08-cv-00369-GMS

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