Free Motion to Dismiss for Failure to State a Claim - District Court of Delaware - Delaware

Case 1:08-cv-00352-SLR

Document 10

Filed 08/08/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE GLORIA M. HARRISON, Plaintiff, v. RENATA J. HENRY, individually and in her official capacity as Director of the Division of Alcoholism, Drug Abuse and Mental Health of the Delaware Department Health and Social Services, SUSAN WATSON ROBINSON, individually and in her official capacity as Hospital Director of the Delaware Department of Health and Social Services, PHILIP THOMPSON, individually and in his capacity as Unit Director of the Delaware Department of Health and Social Services, DELAWARE DEPARTMENT OF HEALTH AND SOCIAL SERVICES, THE DELAWARE PSYCHIATRIC CENTER, and JOHN DOES 1-20, Defendants. : : : : : : : : : : : : : : : : : : : : : : :

Civil Action No. 08-352 (SLR)

DEFENDANTS' MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(1) and 12(b)(6) COME NOW, Defendants Delaware Department of Health and Social Services, the Delaware Psychiatric Center, Renata Henry, Susan Watson Robinson, and Philip Thompson (collectively, the "Defendants"), by and through their undersigned attorney, Kathleen M. Jennings, and move this Honorable Court to dismiss plaintiff Gloria Harrison's complaint. In support of this Motion, the Defendants submit the accompanying Brief and Declaration of Kathleen M. Jennings.

CHL:413146.1/DEL227-253522

Case 1:08-cv-00352-SLR

Document 10

Filed 08/08/2008

Page 2 of 2

WOLFBLOCK LLP /s/ Kathleen M. Jennings Kathleen M. Jennings (No. 913) Joseph C. Schoell (No. 3133) 1100 N. Market Street; Suite 1001 Wilmington, DE 19801 (302) 777-6926 Attorneys for Defendants Dated: August 8, 2008

CHL:413146.1/DEL227-253522

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