Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1 :06-cv-00068-JJF Document 23 Filed 12/27/2006 Page 1 of 4
I ORIGINAL
I IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE
ALVDXLACY, *
Plaintiff, * .
v_ .* Civil Action No.: 1:06-cv-OOO68—JJF
NATIONAL RAILROAD PASSENGER *
CORPORATION ("Al\/ITRAK"), * A ` P
De&ndmu. li
* x * * * * * * * * j‘ Pp
PLAINTIFF ALVIA LACY RESPONSE TO DEFENDANT il i
NATIONAL RAILROAD PASSENGER coRpoRAT1oN's MOTION ~
FOR SUMMARY JUDGMENT V
Plaintiff, Alvia Lacy pro se, moves this court to
deny summary judgment in the Defendant's favor. The material
facts are disputed and Defendant is not entitled to judgement
as a matter of law on Plaintiff's Title VII claim of race and
sex discrimination, and retaliation, because Plaintiff’s
claims are timely and, Plaintiff can establish a prima facie l
case,·and Amtrak discriminatory reason for not promoting
Plaintiff, was based on race and sex. _
WHEREFORE, summary judgment should not be awarded
in favor of Defendant. Plaintiff further requests that the
Court award Plaintiff relief as the Court deems appropriate.

Case 1:06-cv-00068-JJF Document 23 Filed 12/27/2006 Page 2 of 4
In support of this Motion the Court is respectfully
invited to the Response of Plaintiff to Defendant's Motion
for Summary Judgment and supporting exhibits, all filed
herewith.
Respectfully submjEi;2T//HN
Alvia Lacy ppgégg
1306 Jervis Sq.
Belcamp, Maryland 21017
Tel: (410) 272-4819

Case 1:06-cv-00068-JJF Document 23 Filed 12/27/2006 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ALVIA LACY, * V
Plaintiff, * .
v_ * Civil Action No.: l:O6—cv—O0O68—JJF
NATIONAL RAILROAD PASSENGER *
CORPORATION ("AMTRAK"), *
Defendant.

I
WHEREAS, the Court having considered Plaintiff's
· Response to Defendant's Motion for Summary Judgment and the
arguments of both parties related thereto, and the Court
finding material issues of fact and the Defendant is not
l entitled to judgment in its favor,
NOW, THEREFORE, Defendant's Motion is NOT GRANTED
and judgment shall be entered in Plaintiff's favor on all
claims of the Complaint.
t
United States District Court Judge

Case 1:06-cv-00068-JJF Document 23 Filed 12/27/2006 Page 4 of 4
cE1z·1·1F1cA·1·E or sERv1cE
` I HEREBY CERTIFY that on this 26th day 0f December,
2006 a copy of the foregoing Response to Motion for Summary
Judgment and proposed order, were mailed, first class, postage
prepaid to Mr. Darrel VanDeusen, 1823 York Road, Timonium,
Maryland 21093, Counsel for Defendant.
fm Q_Mr`14.Of)l-t Alvia L. Lacy
/20. aa at/7 2
pifiuac, DL we sf