Free Answer to Complaint - District Court of Delaware - Delaware

Case 1:O7—cv—OOO78-JJF Document 14 Filed O4/13/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
_ FOR THE DISTRICT OF DELAWARE
SAM} ALMAKHADHI, )
p _ Plaintiff, l
) C.A. No. l:07·—00O78—.lJF
v. )
)
DELAWARE PARK, ) JURY TRIAL DEMANDED
Defendant. l
ANSWER OF DEFENDANT DELAWARE PARK L.L.C. TO THE COMPLAINT ·
Defendant Delaware Park, L.L.C. (hereinafter “Delaware Park") answers the
. abovedeferenced Complaint as follows:
1. The allegations of this paragraph state legal conclusions to which no
response is required. To the extent a response is required, Delaware Park admits the
Court has jurisdiction to hear this case pursuant to 42 U.S.C. § 2000e—5. Delaware Park
expressly denies that Plaintiff is entitled to any relief sought under 42 U.S.C. § 2000e-5.
2.. The allegations of this paragraph are admitted.
3. The allegations of this paragraph are admitted.
4. It is admitted that Delaware Park employed Plaintiff at 777 Delaware Park
Boulevard, Wilmington, Delaware 19804. The remaining allegations of this paragraph
are denied.
5. The allegations of this paragraph are denied.
A 6. The allegations of this paragraph are admitted. By way of further
response, Delaware Park expressly denies any and all inferences of wrongdoing arising
from the allegations of this paragraph.

Z Case 1 :07-cv-00078-JJF Document 14 Filed O4/13/2007 Page 2 of 3
7. The allegations of this paragraph are admitted.
8. The allegations of this paragraph are admitted.
i 9. Delaware Park is without snfticient information to fonn a belief as to the
date when Plaintiff received his Notice of Right to Sue from the Equal Employment
Opportunity Commission. By way of further response, Delaware Park admits that such
letter was issued on January 16, 2007.
10. The allegations of this paragraph, including all its snbparts, are denied.
ll. The allegations of this paragraph, inclnding all its subparts, are denied.
12. The allegations of this paragraph are admitted. By way of further
response, Delaware Park expressly denies each and every inference or allegation of
wrong doing arising from statements made by plaintiff in the charge of discrimination he
filed with the Equal Employment Opportunity Commission.
l3. The allegations of this paragraph are denied.
S 14. The allegations of this paragraph are denied. By way of further response,
Delaware Park expressly denies that plaintiff is entitled to any remedy for his alleged
harms.
i And further answering, Delaware Park pleads the following additional defenses:
Z FIRST DEFENSE
The Complaint fails to state a claim(s) upon which relief may be granted.
SECOND DEFENSE
I Delaware Park’s actions toward Plaintiff were at all times based on legitimate,
nomdiscriminatory, and non·—retaliatory business reasons.

I Case 1 :07-cv-00078-JJF Document 14 Filed O4/13/2007 Page 3 of 3
THIRD DEFENSE
Plaintiff is not entitled to an award of damages or other legal or equitable relief
. based on the facts and circumstances of this case.
FOURTH DEFENSE
To the extent that Plaintiff seeks to recover damages pertaining to alleged actions
that occurred more than 300 days prior to the filing of his charge of discrimination, such
claims are barred by the applicable statute of limitations.
_ WHEREFORE, Delaware Park requests that the Complaint be dismissed with
prejudice and that Delaware Park be awarded its costs and fees and such other relief as
this Court deems just and proper.
l POTTER ANDERSON & CORROON LLP
I. ._ P .
M /M
Wendy . Voss (#3.r 42)
Kenneth L. ey (#3726)
Jennifer C. Wasson (#493 3)
; Hercules Plaza, 6th Floor
1313 N. Market Street
P.O. Box 951
Wilmington, DE 19899-0951
( (302) 9846000
[email protected]
_ [email protected]
j [email protected]
Dated: April I3, 2007 Attameysfor Defendant Delaware Park,
vsssus x 14672-132 L.L. C.
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Case 1:07-cv-00078-JJF Document 14-2 Filed O4/13/2007 Page 1 of 1 ‘
CERTIFICATE OF SERVICE
I, Wendy K. Voss, hereby certify this 13% day of April, 2007, that the foregoing
. ANSWER OF DEFENDANT DELAWARE PARK, L.L.C. TO THE COMPLAINT
was electronically tiled with U.S. District Court District of Delaware via CM/ECP
(Official Court Electronic Document Filing System) and two (2) tme and correct copies
were sent First Class U.S. Mail, postage prepaid, to the following:
Sami Almakhadhi
200 W. Creek Village E6
Elkton, MD 21921
Wendy K. vet s (#3142)
POTTER AN RSO & CORROON LLP
Hercules Plaza, Sixth Floor
1313 North Market Street
P.O. Box 951 _ -
Wilmington, DE l9899
(302) 984»6000 — Telephone
. (302) 658~1192 ·- Facsimile
[email protected]
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