Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:03-cv-00386-AWT

Document 76

Filed 02/21/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EUNICE SMITH, Plaintiff : : : v. : : STATE OF CONNECTICUT, : DEPARTMENT OF CORRECTION, ET AL: Defendants : CIVIL ACTION No. 3:03CV00386 (AWT)

February 21, 2006

PLAINTIFF'S LOCAL 56 (b) STATEMENT Pursuant to Local Rule 56 (b), Plaintiff submits this statement regarding material facts in dispute. 1. Admit. 2. Admit. 3. Admit. 4. Admit. 5. Admit. 6. Admit. 7. Admit. 8. Admit. 9. Admit. 10. Admit. 11. Admit. 12. Admit. 13. Admit. 14. Admit. 15. Admit. 16. Admit. 17. Admit.

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Case 3:03-cv-00386-AWT

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18. Admit. 19. Admit. 20. Admit. 21. Admit. 22. Admit. 23. Admit. 24. Denied. Plaintiff denies that her arrest was lawful or that she stated to the State Police that keeping the weapon in her vehicle was against DOC policy. 25. Admit. 26. Denied. Plaintiff denies that she failed to provide DOC with appropriate details regarding her arrest in violation of DOC administrative Directive 2.17#5. 27. Admit. 28. Admit. 29. Admit. 30. Admit. 31. Admit. 32. Admit. 33. Admit. 34. Admit. 35. Admit. 36. Admit. FURTHER STATEMENT OF DISPUTED FACTS 1. Plaintiff has filed numerous complaints of discrimination with the CRHO during the course of her employment with DOC (Exhibit 1). 2. Plaintiff wrote numerous letters to Commissioner John Armstrong alleging ongoing discrimination, harassment and retaliation against herself as well as other minority employees within DOC (Exhibit 2). 3. Plaintiff wrote numerous grievances and incident reports regarding incidents of discrimination, harassment and retaliation and processed them through the DOC complaint process (Exhibit 3). 4. Commissioner John Armstrong wrote to Plaintiff on more than one occasion condoning the discriminatory, harassing and retaliatory conduct of DOC personnel toward Plaintiff (Exhibit 4). 5. Plaintiff filed complaints with the DOC Affirmative Action Unit regarding racially harassing incidents (Exhibit 5).

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Case 3:03-cv-00386-AWT

Document 76

Filed 02/21/2006

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6. Plaintiff has been the victim of numerous acts of discriminatory, harassing and retaliatory write-ups (Exhibit 6). 7. Plaintiff participated in a CHRO public hearing regarding investigation of DOC sexual harassment complaints filed with AFSCME (Exhibit 7). 8. Plaintiff experienced discriminatory, harassing and retaliatory conduct from DOC personnel on an on-going basis for her diligent pursuit of grievances on behalf of minority correctional officers (Exhibit 8). 9. Affidavit of Eunice Smith. (Exhibit 9). FOR THE PLAINTIFF EUNICE SMITH BY:_______/S/________________________ Cynthia R. Jennings (Federal Bar No. 21797) THE BARRISTER LAW GROUP, LLC.,
211 STATE STREET, BRIDGEPORT CONNECTICUT 06604 TEL: 203-334-4800 FAX: 203-368-6985

Email: [email protected]

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Case 3:03-cv-00386-AWT

Document 76

Filed 02/21/2006

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CERTIFICATE OF SERVICE
Rev. 12/1/04

Plaintiff [EUNICE SMITH] v. State of Connecticut

) ) ) ) )

Case No. [3:03-cv-00386-AWT]

February 21, 2006

I hereby certify that on [February 21, 2006], a copy of foregoing [Plaintiff's 56(b) Statement of Material Facts] was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /S/Cynthia R. Jennings, Esq., CYNTHIA R. JENNINGS, ESQ.,
THE

BARRISTER LAW GROUP,

LLC.,

211 STATE STREET, BRIDGEPORT CONNECTICUT 06604 TEL: 203-334-4800 FAX: 203-368-6985

Email: [email protected] Federal Bar No. CT21797

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