Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:01-cv-02399-MRK

Document 60

Filed 10/31/2003

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U.S. DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT LAURIE LABONIA Plaintiff V. DORAN ASSOCIATES, LLC, ET AL. Defendant : : : : : : : CASE NO: 3:01 CV 02399 (MRK)

OCTOBER 31, 2003

DEFENDANTS DORAN ASSOCIATES & CHRISTIAN SHELTON'S MOTION FOR SUMMARY JUDGMENT Defendants Doran Associates d/b/a Gardenside Terrace and Christian Shelton hereby move pursuant to Fed. R. Civ. P. 56 and Local Rule 9(c) for summary judgment as to plaintiff's entire complaint, on the following grounds: (1) plaintiff has failed to raise a genuine issue of material fact in support of Count One of her complaint (as narrowed by the Court's dismissal order of May 30, 2002) against Doran Associates, which alleges gender discrimination, sexual harassment, disability discrimination, and unlawful retaliation under federal law; (2) plaintiff has failed to raise a genuine issue of material fact in support of Count Two of her complaint against Doran Associates, which alleges gender discrimination, sexual harassment, disability discrimination, and unlawful retaliation under Connecticut law; (3) plaintiff has failed to raise a genuine issue of material fact in support of Count Two of her complaint against Mr. Shelton, which alleges unlawful retaliation under Connecticut law; and (4) if the Court grants summary judgment as to the federal claims against Doran Associates, it should decline to exercise supplemental jurisdiction over the remaining state law claims. Support for this motion is contained in the accompanying memorandum of law and exhibits. ORAL ARGUMENT REQUESTED

Case 3:01-cv-02399-MRK

Document 60

Filed 10/31/2003

Page 2 of 3

DEFENDANTS DORAN ASSOCIATES AND CHRISTIAN SHELTON

_______________________ Andrew A. Cohen, ct 07124 Letizia, Ambrose & Falls, P.C. One Church Street New Haven, CT 06510 (203) 787-7000

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Case 3:01-cv-02399-MRK

Document 60

Filed 10/31/2003

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing was mailed postage prepaid via first class mail on this 31st day of October 2003 to all counsel and pro se parties of record as follows:

John R. Williams, Esq. Willams and Pattis, LLC 51 Elm Street, Suite 409 New Haven, CT 06510 Phone: 562-9931 Fax: 776-9494 Nicole J. Anker, Esq. Bingham Dana One State Street Hartford, CT 06103-3178 Phone: 860-240-2700 Fax: 860-240-2818 David Casey, Esq. Bingham McCutchen LLP 150 Federal Street Boston, MA 02110-1726 Phone: 617-951-8000 Fax: 617-951-8736

___________________________ Andrew A. Cohen

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