Blogs, Term Papers, and Effective Pedagogy

2012-01-28Since Matt Richtel published “Blogs vs. Term Papers” in the New York Times on January 20, much has been written on the value or lack of value of assigning term papers.  Unfortunately, Richtel confuses the issue by setting up a false dichotomy.  His either/or fallacy forces a debate concerning whether or not blogs are better than term papers.   Instead, we should be discussing if the goals of a particular class might be better met by assigning blogs (or some other research based project) instead of a term paper.

I must admit that during the past few years, I have become less enamored with the primacy of the term paper for reporting on research.  My main problem with the traditional research paper and most other assignments is that they only have an audience of one—the professor.  The second problem is that students adopt the strategy of doing just enough research to write a passing paper.  The goal becomes getting the task completed instead of learning from the research and writing.

When I am assigned to do a mindless piece of writing such as the Final Travel Narrative I am required to submit after attending a conference, I only invest a minimal amount of effort.  Why should I bother to spend time polishing a document that is not going to be read?   Therefore, I do not blame students for not putting forth more effort than is minimally required to write a paper that is only going to be read by the professor.

However, after attending the HASTAC Conference in December 2011, I spent hours drafting my Final Travel Narrative so that it would be a quality piece of writing.  What caused my change in attitude?  What caused me to invest such effort?  The answer is simple.  I had decided to publish my narrative as a blog.

Instead of having virtually no audience, my final narrative—which was published under the title “The Best Professional Development that $150 Could Buy”—was available to colleagues at my college, my students, individuals with whom I interact at HASTAC, and anyone else who finds it on-line.  Given the public audience, the Final Narrative became a serious piece of writing and I therefore treated it seriously.

Over the years, I have done what I could to give students a public venue to display the results of their research.  Generally, I have done this with poster sessions open to the college community.  But, this semester I am experimenting with multi-author blogs that will allow students to share their writing with a larger community outside our classroom, asking students to create a website on student success, and encouraging them to do identify other venues for publication.    In fact, during Winter semester, I have built the expectation into my courses that most major assignments will be published.

Because students are thinking in terms of publication,  they are already taking a more serious approach to their research.  For example, one of my undergraduate students is conducting preliminary research that will lead to a very valuable article which will assist the graduate students and university faculty members who are the primary readers of HASTAC blogs.  Even during their first day in the library, students working on the Ocelot Scholars project are already framing their research in terms of how it could benefit others.  From day one, writing for the professor–an audience of one–is not their goal.

Richtel and others who argue for the primacy of term papers incorrectly assume that blogs are somehow frivolous or do not rely on research.  A well written, well documented blog entry could require even more research and writing than a traditional term paper or documented essay.  The analyses assigned to my film students serve as an example.  While I do not really care where students publish their film analyses this semester, I care greatly that academic research is incorporated into the analyses.  Without serious research, students will not get credit for their blog entries.  Asking them to write blogs is not asking them to sacrifice academic content.

Arguing about the form in which the research is presented—blog, term paper, video, et cetera—is not very useful.  We need a discussion about the virtue of publication and the benefits that result from students interacting with a real audience; something that is generally not possible with the traditional term paper assignment.

By publishing blogs instead of traditional research papers, students can write for real audiences, get real feedback, and contribute to real academic discussions.  And, like me, they will put more effort into assignments designed for publications than they will for papers or Final Travel Narratives which have virtually no audience.

–Steven L. Berg, PhD



Suggestions for Further Reading

Bauerlein, Mike. “Blogs and Term Papers” (Chronicle of Higher Education. 23 January 2012).

Davidson, Cathy N.  “Davidson at Dartmouth: ‘Distraction is Our Friend‘” (YouTube video).

Davidson, Cathy N.  “Should We Really ABOLISH the Term Paper?  A Response to the New York Times” (HASTAC. 21 January 2012).

Fister, Barbara. “This Short Blog Post is All About Me or, Term Papers on Trial — Again“  (Inside Higher Ed. 2 January 2012).

Jacobs, Alan. “Are Research Papers Obsolete?” (Atlantic, 25 January 2012).

Marshall, Eric. “Blogs in Class.”  (A Memorable Fancy, 21 January 2012).

Pannapacker, William.  “Invisible Gorillas Are Everywhere” (Chronicle of Higher Education.  23 January 2012).

Richtel, Matt. “Blogs vs. Term Papers” (New York Times. 20 January 2012).



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Blogs, Term Papers, and Effective Pedagogy” has been cross posted at HASTAC.

3 Responses

  1. Sandy Roney-Hays says:

    As the original post and the post by Sam Hays make clear, research can be effectively incorporated in diverse formats.

    Blogging as a classroom approach challenges the instructor as well as the students, and can obviously bring new types of rewards. It seems incumbent upon us, as instructor/learners to use all of the skills at our disposal to adapt to a hyper-connected world in many ways, communication being one of the most crucial. Our students must also learn to take hyper-connectivity and global competition seriously.

    I wish we had thought of incorporating a short video presentation on your research blogging at the Global Roundtables, “A Global Wake-Up Call,” on Monday, March 19th! Although we are not organizing the Roundtables specifically around the core abilities we use at Schoolcraft, we are operating under the assumption that the core abilities ought to be consciously “marketed” to students, and expanded upon in new ways so that students will REALLY make them part of their lives, We are all being forced to adjust, and challenged to flourish, in a quickly evolving global world in which every person is “other.” You are helping us all do that with the “communication” core ability. Thanks!!!

  2. […] wrote “Blogs, Term Papers, and Effective Pedagogy” which I cross posted in Etena Sacca-vajjena and at […]

  3. Sam Hays says:

    My brother with only a high school education researches regularly on health food and healthy environment. Recently he has sued a small West Virginia town for tresspassing his 14th Amendment rights. It is now in federal court. he is his own lawyer. Here is his latest court appeal.

    PONSE IN OPPOSITION AND REQUEST FOR SANCTIONS.docx
    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

    CHARLESTON DIVISION

    RODNEY E. HAYS, Pro Se
    Plaintiff,

    v.

    Civil Action No. 2:09-1272

    Honorable John T. Copenhaver, Jr.

    TOWN OF GAULEY BRIDGE, WEST VIRGINIA,
    a West Virginia Municipal Corporation,WILLIAM KINCAID,
    individually and in his official capacity as Judge of the Gauley Bridge
    Municipal Court, SEAN WHIPKEY, individually and in his official
    capacity as a Town of Gauley Bridge Police Officer, HEATH WHIPKEY,
    individually and in his official capacity as a Town of Gauley Bridge Police Officer,
    CHARLES BURKHAMER, individually and in his official capacity as a Town of
    Gauley Bridge Police Officer,

    Defendant’s.

    PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANTS’ MOTION AND MEMORANDUM IN SUPPORT OF MOTION TO ENFORCE OFFER OF JUDGMENT AND FOR COSTS; AND PLAINTIFF’S NOTICE AND REQUEST FOR SANCTIONS AGAINST THE DEFENDANT’S LAWYER AND LAW FIRM

    The Plaintiff Pro Se Rodney E. Hays responds in opposition to the Defendant’s request for costs. The Plaintiff respectfully requests that the Court deny their Motion to enforce their offer of judgment and for costs, and that the Court award the Plaintiff “Sanctions” against the Defendant’s lawyer and Law Firm to pay for the Pro Se Plaintiff’s Costs, Fees, and Expenses in this Civil case.

    The Defendant’s lawyer has made a lot of frivolous and harassing legal arguments, in Docket 6 and 7, the Defendant’s Motion and Memorandum did not include one case about a “Right to a Public Trial” under the Sixth Amendment to the U.S. Constitution, the Federal Rules of Civil Procedure Rule 11(b) states:

    (b) Representations to the Court. By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it—an attorney or unrepresented party certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances: (1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law; (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and (4) the denials of factual contentions are warranted on the evidence or, if specifically so identified, are reasonably based on belief or a lack of information. (c) Sanctions. (1) In General. If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation. Absent exceptional circumstances, a law firm must be held jointly responsible for a violation committed by its partner, associate, or employee. (2) Motion for Sanctions. A motion for sanctions must be made separately from any other motion and must describe the specific conduct that allegedly violates Rule 11(b). The motion must be served under Rule 5, but it must not be filed or be presented to the court if the challenged paper, claim, defense, contention, or denial is withdrawn or appropriately corrected within 21 days after service or within another time the court sets. If warranted, the court may award to the prevailing party the reasonable expenses, including attorney’s fees, incurred for the motion. (3) On the Court’s Initiative. On its own, the court may order an attorney, law firm, or party to show cause why conduct specifically described in the order has not violated Rule 11(b). (4) Nature of a Sanction. A sanction imposed under this rule must be limited to what suffices to deter repetition of the conduct or comparable conduct by others similarly situated. The sanction may include nonmonetary directives; an order to pay a penalty into court; or, if imposed on motion and warranted for effective deterrence, an order directing payment to the movant of part or all of the reasonable attorney’s fees and other expenses directly resulting from the violation.

    The U.S. Supreme Court stated: “[A]n attorney’s ethical duty to advance the interests of his client is limited by an equally solemn duty to comply with the law and standards of professional conduct.” Nix v. Whiteside, 475 U.S. 157, 168, 106 S.Ct. 988, 89 L.Ed.2d 123 (1986). Lawyers face sanctions, among other things, for suits presented “for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation.” Fed. Rules Civ. Proc. 11(b), (c). Model rules of professional conduct adopted by many States impose outer bounds on an attorney’s pursuit of a client’s interests. See, e.g., ABA Model Rules of Professional Conduct 3.1 (2009) (requiring nonfrivolous basis in law and fact for claims asserted); 4.1 (truthfulness to third parties). In some circumstances, lawyers may face personal liability for conduct undertaken during representation of a client. See, e.g., Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N. A., 511 U.S. 164, 191, 114 S.Ct. 1439, 128 L.Ed.2d 119 (1994) (“Any person or entity, including a lawyer, . . . who employs a manipulative device or makes a material misstatement (or omission) on which a purchaser or seller of securities relies may be liable as a primary violator under [Securities and Exchange Commission].”

    The Fourth Circuit has recently upheld a District Courts ruling on an award of “Sanctions” for Professional Misconduct against a lawyer(s). 650 F.3d 423 (2011) NEWPORT NEWS HOLDINGS CORPORATION, Plaintiff-Appellee, v. VIRTUAL CITY VISION, INCORPORATED, d/b/a VCV Inc.; Van James Bond Tran, Defendants-Appellants. No. 09-1947. United States Court of Appeals, Fourth Circuit.

    The U.S. Court of Appeals for the Fourth Circuit stated:

    In any event, even assuming that the notice of appeal was proper, the court’s award of sanctions does not merit reversal. Section 1927 states: “Any attorney . . . who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” 22 U.S.C. § 1927″A district court’s decision to impose sanctions is entitled to `substantial deference'” because “[a] district court `is in the best position to review the factual circumstances and render an informed judgment as [it] is intimately involved with the case, the litigants, and the attorneys on a daily basis.'” Blue v. U.S. Dept. of Army, 914 F.2d 525, 538 (4th Cir.1990).The district court found that VCV’s “Motion for Recusal was made recklessly and in bad faith” and that VCV “more likely than not acted in bad faith in seeking leave to file its counterclaim.” J.A. 2132. It concluded that VCV’s counsel “engaged in a pattern of behavior to delay the resolution of this case and . . . unreasonably and vexatiously multiplied the proceedings.” Id. at 2134. Relying on the facts we have already outlined, and given the motions’ significant substantive weaknesses as well as their suspicious timing, we cannot say that the district court clearly erred in its factual finding that they were filed with the purpose of multiplying proceedings. See United States v. Wallace, 964 F.2d 1214, 1217 (D.C.Cir. 1992) (describing a finding of bad faith as a factual finding reviewable for clear error). We therefore hold that the district court’s award of sanctions was not an abuse of discretion.

    28 U.S.C. § 1927. COUNSEL’S LIABILITY FOR EXCESSIVE COSTS

    Any attorney or other person admitted to conduct cases in any court of the United States or any Territory thereof who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.

    The Defendant’s lawyer has clearly made a lot of frivilous and harassing legal arguments, that were not supported by law. The Defendant’s lawyer has multiplied the proceedings unreasonably and vexatiously. The Defendant’s lawyer thinks, that the state of WV still has “justices of the peace” and that Municipal Judges are the same as a justice of the peace and that Municipal Court Judges and Municipal Courts have concurrent jurisdiction with the Magistrate Court of Fayette County, WV, See Doc. 28 and Doc. 40., and Doc. 55 and 56, the Defendant’s lawyer makes a frivolous and harassing argument and multiplies the pleadings unreasonably and vexatiously in Doc. 55 and 56 the Defendant’s lawyer states:

    Furthermore, W.Va. Code § 17C-19-9 states that “Justices of the peace shall have concurrent jurisdiction with the circuit, criminal and intermediate courts to enforce the misdemeanor penalties prescribed by this chapter.” The Plaintiff argues that, because there are no longer any Justices of the peace, municipal judges are only able to enforce municipal laws and ordinances. See Exhibit A at 11. The phrase ‘Justice of the peace” is an outdated moniker. For the purposes of clarification, the Supreme Court of Appeals has held that Mayors and municipal court judges have the same powers as a justice of the peace. See State ex rel. Hill v. Smith, 172 W.Va. 413, 14, 305 S.E.2d 771, 772 (1983). Therefore, the municipal court judges have jurisdiction over violations of Chapter 17C of the West Virginia Code. Further, Judge William Kincaid, a municipal judge, has concurrent jurisdiction over charges of speeding violations that occur within the boundaries of the municipality. See W.Va. Code § 17C-19-9. (Doc. 56, pg. 7 Def. Memorandum in support of Motion for Summary Judgment).

    That is not true, under the WV Constitution Article 8-11, the WV Constitution Article 8-11 states:

    8-11. Municipal courts. The Legislature may provide for the establishment in incorporated cities, towns or villages of municipal, police or mayors’ courts, and may also provide the manner of selection of the judges of such courts. Such courts shall have jurisdiction to enforce municipal ordinances, with the right of appeal as prescribed by law. Until otherwise provided by law, all such courts heretofore established shall remain and continue as now constituted, and with the same right of appeal, insofar as their jurisdiction to enforce municipal ordinances is concerned; but on and after January one, one thousand nine hundred seventy-seven, any other jurisdiction now exercised by such courts shall cease. No judge of a municipal, police or mayor’s court or any officer thereof shall be compensated for his services on a fee basis or receive to his own use for his services any pecuniary compensation, reward or benefit other than the salary prescribed therefor.

    The Plaintiff has had to argue against the Defendant’s frivolous and harassing arguments through the whole case for over two years.

    ABA Maintaining The Integrity Of The Profession

    Rule 8.4 Misconduct

    It is professional misconduct for a lawyer to

    (a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;

    (b) commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects;

    (c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation;

    (d) engage in conduct that is prejudicial to the administration of justice;

    (e) state or imply an ability to influence improperly a government agency or official or to achieve results by means that violate the Rules of Professional Conduct or other law; or

    (f) knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.

    WEST VIRGINIA RULES OF PROFESSIONAL CONDUCT, Rule 3.1 states:

    Rule 3.1 Meritorious Claims and Contentions (a) A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis for doing so that is not frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for the defendant in a criminal proceeding, or the respondent in a proceeding that could result in incarceration, may nevertheless so defend the proceeding as to require that every element of the case be established.

    LR Civ P 83.7. Codes of Professional Conduct

    In all appearances, actions and proceedings within the jurisdiction of this court,

    attorneys shall conduct themselves in accordance with the Rules of Professional

    Conduct and the Standards of Professional Conduct promulgated and adopted by the

    Supreme Court of Appeals of West Virginia, and the Model Rules of Professional

    Conduct published by the American Bar Association. Judicial officers of this court

    must comply with the Code of Conduct for United States Judges adopted by the

    Judicial Conference of the United States; judiciary employees of this court must

    comply with the Code of Conduct for Judicial Employees, also adopted by the

    Judicial Conference.

    During the last Mediation Conference, the Defendant’s lawyer Vaughn T. Sizemore said that the Plaintiff had to pay half of the Mediator’s Fee’s when the Plaintiff never agreed to hire and to pay for that Mediator under LR Civ P 16.6.2., LR Civ P 16.6.7., the Mediator and Vaughn T. Sizemore both ganged up on the Plaintiff and told the Plaintiff that he had to pay them, which isn’t a true statement, they were trying to take advantage of the Pro Se Plaintiff, the law says that the Plaintiff doesn’t’ have to pay half of the Mediator’s Fee’s, the Plaintiff never agreed to pay half.

    During the Plaintiff’s Civil Jury Trial the Defendant’s lawyer made some “false statements” about the Plaintiff Rodney E. Hays, the Defendant’s lawyer said that the Plaintiff committed “tax fraud” without any evidence to support those statements, the Defendant’s lawyer isn’t the IRS, the Plaintiff stated that he does fill out his tax returns every year and that he obeys the IRS tax code relating to paying any taxes that he owed to the IRS, the Plaintiff did not commit tax fraud. This was a false statement and an improper statement about the Plaintiff, by the Defendant’s lawyer, the Defendant’s lawyer misrepresented the facts, evidence, and laws of the case, the Defendant’s lawyer is liable for “Professional Misconduct” under the Federal Rules of Civil Procedure Rule 11(b), 28 U.S.C. § 1927, ABA Maintaining The Integrity Of The Profession Rule 8.4 Misconduct, WEST VIRGINIA RULES OF PROFESSIONAL CONDUCT, Rule 3.1, LR Civ P 83.7, Codes of Professional Conduct, ABA Rule 3.4(e) Fairness To Opposing Party And Counsel.

    ABA Rule 3.4 Fairness To Opposing Party And Counsel:
    (e) in trial, allude to any matter that the lawyer does not reasonably believe is relevant or that will not be supported by admissible evidence, assert personal knowledge of facts in issue except when testifying as a witness, or state a personal opinion as to the justness of a cause, the credibility of a witness, the culpability of a civil litigant or the guilt or innocence of an accused;
    Sanctions are justified in this case against the Defendant’s lawyer and Law Firm, the Plaintiff is entitled by law to “Sanctions” against the Defendant’s lawyer and law firm.
    During the civil jury trial one of the Defendant’s witnesses Police Chief Sean Whipkey mislead the jury, confused the issues, and misrepresented the facts and laws of the case, Chief Whipkey kept telling the jury that the Town of Gauley Bridge Police Department uses radar as “secondary evidence” when in fact they used it as “primary evidence” as the only evidence to Unlawfully stop, and Illegally Seize the Plaintiff Rodney E. Hays, and to issue the Plaintiff an illegal speeding ticket, and Maliciously Prosecute the Plaintiff, the Defendant Police Chief Whipkey used radar as Prima Facie Evidence, when he wasn’t authorized to in 2009 under the WV Code 17C-6-7. The District Court stated in Docket 72:

    Further, the fact that the amended statute precludes the police departments of Class IV municipalities from proving vehicular speeding on certain highways via radar gun evidence also demonstrates that the Defendants’ “probative evidence” interpretation is without merit. There was no provision in State law in 2009 which allowed the introduction of radar gun evidence obtained by a Class IV municipal police officer. (Doc. 72, PF&R pg. 14). (Doc. 75, MO&O pg. 10).

    The District Court stated in Docket 75:

    As the magistrate judge correctly notes, neither West Virginia Code section 17C-6-7 nor any other “provision in State law in 2009 . . . allowed the introduction of radar gun evidence obtained by a Class IV municipal police officer.” (PF&R at 14) (Doc.75, MO&O pg. 17) as the magistrate judge notes, without objection from defendants, the use of the radar device and Municipal Judge William Kincaid’s services violated state law. (Doc.75, MO&O pg. 17).

    One of the Defendant’s witnesses Brian Parsons a licensed lawyer in two states, the state of WV and OH, intentionally mislead the jury, confused the issues, and misrepresented the facts, evidence, and laws of the case, as stated above the U.S. District Court has previously ruled, that Police Officers of a Class IV Town or Village in 2009 were not authorized under the WV Code 17C-6-7 to use Radar as Prima Facie Evidence to prove the speed of automobiles for speeding violations. As noted above the District ruled that the Defendant’s probative evidence argument was without merit. Brian Parsons kept arguing for an attorney general’s opinion to try to make the Gauley Bridge Illegal Speed Trap a legal speed trap, when the District has already ruled on that legal issue. Brian Parsons conduct was unethical.

    The Plaintiff’s witness Thornton Cooper who is a licensed lawyer, Mr. Cooper did not mislead the jury or confuse the issues, and did not misrepresent the facts, evidence, or laws. The Plaintiff did not mislead the jury or confuse the issues, and did not misrepresent the facts, evidence, or laws.

    Pro Se litigants are to be held to less stringent standards as licensed lawyers, Courts have been more lenient on Pro Se litigants See, Erickson v. Pardus, 127 S. Ct. 2197 – Supreme Court 2007 and Haines v. Kerner, 404 US 519 – Supreme Court 1972., Tabron v. Grace, 6 F. 3d 147 – Court of Appeals, 3rd Circuit 1993, “Tabron was a pro se litigant before the district court, and we have traditionally given pro se litigants greater leeway where they have not followed the technical rules of pleading and procedure.” See Riley v. Jeffes, 777 F.2d 143, 147-48 (3d Cir.1985); Siers v. Morrash, 700 F.2d 113, 116 (3d Cir.1983).

    The Plaintiff Pro Se Rodney E. Hays is “Exempt” from paying the Defendant’s any costs or fees or expenses under American Law, Pro Se litigants aren’t entitled to attorney fees if they prevail under American Law. The Plaintiff Pro Se under American Law does not owe the Defendant’s or their lawyer or law firm anything.

    The Plaintiff Rodney E. Hays respectfully requests that the Court “Sanction” the Defendant’s lawyer and Law Firm, and that the Court award the “Sanctions” to pay for all of the Plaintiff’s Costs and Fees and Expenses related to the Plaintiff’s Civil case, and that the Plaintiff Pro Se does not owe the Defendant’s or the Defendant’s lawyer or law firm any Costs, Fees, or Expenses.

    Signed on January 03 , 2012

    4916 Jonquil Drive

    Charleston, WV 25306

    765-580-1786

    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

    CHARLESTON DIVISION

    RODNEY E. HAYS, Pro Se

    Plaintiff,

    v.

    Civil Action No. 2:09-1272

    Honorable John T. Copenhaver, Jr.

    TOWN OF GAULEY BRIDGE, WEST VIRGINIA,

    a West Virginia Municipal Corporation,WILLIAM KINCAID,

    individually and in his official capacity as Judge of the Gauley Bridge

    Municipal Court, SEAN WHIPKEY, individually and in his official

    capacity as a Town of Gauley Bridge Police Officer, HEATH WHIPKEY,

    individually and in his official capacity as a Town of Gauley Bridge Police Officer,

    CHARLES BURKHAMER, individually and in his official capacity as a Town of

    Gauley Bridge Police Officer,

    Defendant’s.

    CERTIFICATE OF SERVICE

    I HEREBY CERTIFY that a true and correct copy of foregoing

    PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANTS’ MOTION AND MEMORANDUM IN SUPPORT OF MOTION TO ENFORCE OFFER OF JUDGMENT AND FOR COSTS; AND PLAINTIFF’S NOTICE AND REQUEST FOR SANCTIONS AGAINST THE DEFENDANT’S LAWYER AND LAW FIRM

    was served upon the following by first class mail to:

    BAILEY & WYANT, PLLC

    Attn: Vaughn T. Sizemore

    500 Virginia Street, East, Suite 600

    Post Office Box 3710

    Charleston, West Virginia 25337-3710

    Done this 3rd day of January 2012.

    4916 Jonquil Drive

    Charleston, WV 25306

    765-580-1786

    Plaintiff, Pro Se

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