Clemons v. Google, Inc.

Filing 7

MOTION to Reissue Summons by Richard Clemons. (dvanm, )

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MA!I ROOr'TI

United states District Court
Eastern District of Alexandria

OCT - 3 2017
CLERK, U.S. DISTRICT COURT
ALEXANDRIA. VIRGINIA

Richard demons

file no. 1:17cv963

Plaintiff

Hon.

V

Google Inc.
Defendant

IVIotion to Reissue Summons
Now comes plaintiff and states as follow:
That on 9-12-17 the U.S IVlarshal returned said summons in this case

unexecuted. The execution being reduced to address change of defendant;

plaintiff moves the court administratively to reissue the summons to the
defendant at

Google Inc.
1000 Enterprise Way

Sunnydale, CA 94098.
Richard Clemo

Fbiloyal707@

ail.com

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MA!1 ROOM

OCT -3 2017

United States District Couit
jCLERK, U.S. District court

Eastern District of Alexandria Virginlsf

ALEXANDRiA. VIRGiiMIA

File no. 1:17-cv-824

Richard demons
Plaintiff

Hon.

V

Jane Ampah
Defendant
N

Response to Defendant's
Answer.
Now comes Plaintiff and states as follow:

1) That the defendant answered this complaint on 9-12-17 with a
standard denial; in that there was no affidavit supporting defendant's
denial and counsel provided not one case citation in support of his
conclusions that plaintiff has not stated a claim for relief

2) Plaintiff reasserts that defendant as a state employee may not utilize
official state action in an unlawful manner in retaliation for plairitiff

exercising his rights to the grievance mechanism and that this is
clearly established law in the commonwealth of Virginia and in U.S.
Supreme Court law.

3) Defendant's answer demonstrates nothing but a genuine issue of
material fact to be resolved by trial.

Respectfully Submitted,
Richard demons
Fbiloval707@amaill com

PROOF OF SERVICE

Plaintiff forwarded a copy of above on defendant at thdit
Listed place of business via first class prepaid mail_

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