Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-00695-AVC

Document 19

Filed 02/04/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
LORRAINE H. MULLIGAN, Plaintiff, VS. SUNBRIDGE HEALTHCARE CORPORATION d/b/a MEDIPLEX OF STAMFORD Defendant. : : : : : : : : : CIVIL CASE NO. 3:03CV695(AVC)

FEBRUARY 3, 2004

MOTION TO AMEND PLAINTIFF'S COMPLAINT PURSUANT TO RULE 15(a) OF THE FEDERAL RULES OF CIVIL PROCEDURE
Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, the plaintiff respectfully requests that the Court allow her to amend her complaint to add additional causes of action claiming (1) unlawful race and color discrimination in violation of Title VII of the Civil Rights Act of 1964, as amended, and (2) unlawful race and color discrimination in violation of the Connecticut Fair Employment Practices Act. A copy of the plaintiff's amended complaint

containing the additional cause of action is appended. The plaintiff states that there exists good cause to allow her amendments for the following reasons: 1. At the time the plaintiff brought this cause of action, her claim based on race and color discrimination arising pursuant to the provisions of Title VII of the Civil Rights Act of

Case 3:03-cv-00695-AVC

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Filed 02/04/2004

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1964, as amended, had not as yet ripened. On December 12, 2003, the United States Equal Employment Opportunity Commission issued to the plaintiff a "Notice of Right to Sue", allowing her to institute a court action in this court within 90 days. 2. At the time the plaintiff brought this cause of action, her claim based on race and color discrimination arising pursuant to the provisions of the Connecticut Fair Employment Practices Act had not as yet ripened. On December 12, 2003, the Connecticut

Commission on Human Rights and Opportunities issued the plaintiff a "Release of Jurisdiction" allowing her to institute a court action in this court within 90 days. WHEREFORE, the plaintiff moves that the Court grant her motion to amend her Complaint pursuant to the first substituted complaint attached hereto. THE PLAINTIFF ­ LORRAINE H. MULLIGAN

BY______________________________________ Thomas W. Bucci, for WILLINGER, WILLINGER & BUCCI, P.C. 855 Main Street Bridgeport, CT 06604 Tel: (203) 366-3939 Fax: (203) 337-4588 Email: [email protected] Fed. Bar #ct07805

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Case 3:03-cv-00695-AVC

Document 19

Filed 02/04/2004

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CERTIFICATION I hereby certify that copies of the foregoing Motion to Amend Plaintiff's Complaint Pursuant to Rule 15a of the Federal Rules of Civil Procedure have been sent, by First Class Mail, postage prepaid, on this 3rd day of February 2004, to: Margaret Armstrong Weiner, Esquire JACKSON LEWIS LLP 177 Broad Street P.O. Box 251 Stamford, CT 06904-0251 Tel: 203-961-0404 Fax: 203-324-4704 Federal Bar No. ct18084 Email: [email protected] __________________________________ Thomas W. Bucci

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