S Michael R. Robinson
_ Phone: (302)-121-6895
I I Fax: (302)421—588S
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June l2, 2008
VIA E-FILE & HAND DELIVERY it -
The Honorable Gregory M. Sleet jr E
United States District Court i JUN `1 8 ZUCB
844 North King Street ' , j
Wilmington, DE 19801 ‘gf;““·, .;;~ *}‘_ ,·Kj=,j~ {
DISTHICTO; ULLLAWAFQL `
Re: Coppedge v. Yurkie, C.A. N0. 1:07-cv-846-GMS·MPT
Coppedge v. City 0f Philadelphia, C.A. N0. 07-684-GMS-MPT
Coggedge v. Leatherman, C.A. N0. 07-763-GMS-MPT
Dear Chiefludge Sleet:
1 write on behalf of the defendants in the above-captioned matters (collectively
"Defendants") in response to several Affidavits and other_papers..proiiir:1ed by plaintiff
James Coppedge. Specifically, Mr. Coppedge has ifCerti*Hcatioh"of;Vl}ion-Response,
tiled in C.A. No. 07-684 (D.1. 26), an Affidavit Default Judgment and
a Certification of Non-Response, filed in 7-763 (D.I“i 25 and D.1. 26, respectively), ind a
Certification ot`Non—Response tiled in C.A. No. 07-846 (D.l. 17). L J
These filings reflect once again Mr. Coppedge`s continued pattem of abuse ofthe
judicial process and should be disregarded by the Court.] See Letter to the Court of
March 18. 2008 in C.A. No. 07-684 (D,]. 24), in C.A. No. 7-763 (D.l. 23). and in C.A.
No. 07-846 (D1. 13). Coppedgeagain has failed to heed the Court`s wanting late
last year that until the Court rules*in"“1iis favor, such "repetitive motions or petitions [to
enter judgment] wi11=.not`be consideredyan ··will be summarily denied." Order dated
12/ 1 1/2007, C.A. N_q,_ 07-684_(QtI,, 1* As there are pending meritorious motions to
dismiss in each-_of` these imafteicsflt e Court has obviously not ruled in Mr. Coppedge’s
favor. Thus, res ectful,ly;'iMr. jCoppedge’s continued filings in the referenced cases
should be disregarggg/Hy the Court and "summarily denied?
I For some unknown reason, Mr. Coppedge filed my letter of March 18, 2008 with
a stamp indicating that it was being "accepted for value," in the three cases. e / C By;
C.A. No. 07-684 (D.I. 25), in C.A. No. 7-763 (D.I. 24). and in C.A. No. 0/7 I6 W/fir;
(D.l. 14). lt is unclear what Mr. Coppedge meant by that statem tg/_, hus, o-{
i I Defendants are unable to respond to it. To the extent that Mr. Coppe@e maygbe U
ty;} asserting some sort of contractual relationship, Defendants ex réssly 6* Wd
such relationship exists between Mr. Coppedge and defendarttg £int ,5 . **69
, x @;<¢1¢°¢
P O Box 1266 • Wilmington, DE 19899-1260 • Phone {302) -121-6800 • Fax t302) Ulgjyw
Courier Address 222 Delaware Axenue, Suite 1200 • Wilmington, DE 19801-1611 @4 8, 7
BAL`l`1}~1ORE (`HESTERBROOK HARRISBURG NE\\ ARK PHILADELPHIA PRINCETON WASHIN N
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4 Thé3§ggOté(g7éc%¥§gé)OE;84k'hQ§q§€t Document 28 Filed 06/18/2008 Page 2 of 3
United States District Coun
June 12, 2008
“ Page 2
As Mr. Coppedge has not discontinued his harassment of the City of Philadelphia
(the "City"), its employees, and now its legal counsel, Defendants respectfully request
that the Court impose sanctions against Mr. Coppedge, or, at the very least, discontinue
receiving filings from him. Courts faced with similar frivolous lawsuits have found that
sanctions and an injunction of filings are proper remedies to address the sort of abuse of
process Mr. Coppedge has engaged in. Sy, _gg,, United States v. Kettler, 934 F.2d 326
(10th Cir. 1991) (imposing restrictions on future filings without express permission);
United States v. McKinley, 53 F.3d 1170 (10th Cir. 1995) (granting request for sanctions
and imposing injunction against future filings without express permission); United States
v. Barker, 182 P.R.D. 661 (S.D. Ga. 1998) (same); United States v. Barker, 19 F.Supp.2d
1380 (S.D. Ga. 1998) (enjoining future filings without express permission and enjoining
party from tiling commercial liens based on failure to respond to a document against
federal employees); United States v. Andra, 923 F.Supp. 157 (D. ld. 1996) (same);
Stoecklin v. United States, 1997 WL 1039238 (M.D. Fla. 1997) (imposing sanctions for
continued filing of frivolous motions). True and correct copies of these opinions are
attached alphabetically at Exhibit A.
The rationale upon which courts have imposed sanctions and enjoined future
filings in similar situations is equally applicable here. This is especially so in light of
Mr. Coppedge’s recent targeting of Saul Ewing with yet another frivolous and improper
lawsuit instead of waiting for the disposition of the pending motions in the referenced
cases. y Coppedge v. Saul Ewing, C.A. No. 08—289. Mr. Coppedge’s mercenary use
of litigation as a tool to intimidate and harass the City, its employees, and now their legal
counsel, for doing their jobs is exactly the sort of behavior courts around the country have
refused to condone and consider sanctionable. Like those courts, this Court should not
allow (and, thereby, further encourage) Mr. Coppedge’s continued excessive,
inappropriate actions and intentional waste of resources by both this Court and
Defendants.
As always, counsel remains available at the Court’s convenience if Your Honor
has any questions.
Respectfully,
Cx
Michael R. Robinson
(Del. Bar No, 4452)
cc: Mr. James Coppedge
(Via First Class U.S. Mail)
559613 26/12/08
Case 1 :07-cv—OO684-GIVIS Document 28 Filed Q6/18/2OO Page 3 0f 3
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Case 1:07-cv-00684-GMS
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