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Case 1:08-cv—00295-G|\/IS Document 41 Filed 08/26/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE
DISTRICRT OF DELAWARE
NINA SHAHIN l
Plaintiff )
v. ) Civil Action No. 08-295 GMS
)
PAMELA A. DARLING et al )
Defendant )
PLAINTIFF’S WITHDRAWAL OF MOTION FOR SAN CTIONS
AGAINST THE ATTORNEY, RICHARD H. MORSE, UNDER RULE
11 OF FEDERAL RULES OF CIVIL PROCEDURES
The Plaintiff, Nina Shahin, thereby withdraws her Motion for Sanctions against
the attomey representing the firm of Young Conaway, Stargatt and Taylor LLP, Mr.
Richard H. Morse.
After careful examination of the case law and different legal commentaries related
to the legal issue raised in the Motion for Sanctions the Plaintiff have to admit that the
private course of action under Bivens is accorded only against the federal employees.
Violations of constitutional rights by state employees are to be brought under the Civil
Rights Act of 1871 (42 USC. § 1983). Since the Plaintiffs accusations against most of
the judges are based on Racketeer Influenced and Corrupt Organization Act, the Civil
Rights of 1871 has a relatively minor importance although Federal Courts Improvement
Act of 1996 also has relevance to the Plaintiff s case.
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Case 1 :08-cv—00295-GIVIS Document 41 Filed 08/26/2008 Page 2 of 4
The Plaintiff, therefore, withdraws her Motion and offers her apology for that
premature Motion that was caused by the pressure of deadline and the acute shortage of
time to research the issue before the submission of the Motion.
Submitted on this 25th day of August of 2008. 7
For Plaintiff: .
Nina Shahin
103 Shinnecock Rd.
Dover, DE 19904
Tel. # 302-678-1805
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Case 1 :08-cv—00295-GIVIS Document 41 Filed 08/26/2008 Page 3 of 4
CERTIFICATE OF SERVICE
I, NINA SHAHIN, CPA
Hereby certify that one true copy of this WITHDRAWAL OF THE PLAINTIFF’S
MoT1oN FOR SANCTIONS AGAINST THE ATTORNEY, RICHARD H.
MORSE, UNDER RULE 11 OF FEDERAL RULES OF CIVIL
PROCEDURES have been mailed today, August 25th, 2008 by a first class mail to the
attorneys at the following addresses:
Kevin R. Slattery
Deputy Attorney General
Carvel State Office Building
829 North French Street! 6th Floor
Wilmington, DE 19801
Richard H. Morse
Yotmg Conaway Stargatt & Taylor LLP
The Brandywine Building
1000 West Street, 17th Floor
Wilmington, DE 19899-0391
Norman H. Brooks, Jr.
Marks, O’Neal, O’Brian & Courtney, P.C.
913 North Market St., Suite 800
Wilmington, DE 19801
Theodore John Segletes, III
Marks, O’Neal, O’Brian & Courtney, P.C.
913 North Market St., Suite 800
Wilmington, DE 19801
Original and one true copy were mailed to the ` trict Court by a certified mail
with a return receipt. , I
Date: August 25***, 2008 .
Nina Shahin, CPA
3

Case 1 :08-cv—00295-GIVIS Document 41 Filed 08/26/2008 Page 4 of 4
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Federal District Court for the District of Delaware
844 North King Street
Wilmington, DE 19801-3570
Attn.: Clerk ofthe Civil Section

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