Free Response to Motion - District Court of Delaware - Delaware

Case 1:04-cv—O1554-SLR Document 24 Filed O3/O9/2006 Page1 of 4
TO: PETER T. DALLEO, CLERK
UNITED STATES DISTRICT COURT
344 KING STREET, LOCKBOX 18
WILMINGTON, DE 19801
(302)573—6170
FROM: RENEE W. BYRD
2334 TOLSTOY LANE
NEWARK, DE 19702
(302)834 — 2123
COPY TO: DANIEL P. BENNETT
DELAWARE BAR #2842
THE COPORAT E PLAZA
800 DELAWARE AVENUE, SUITE 200
P.O. BOX 128
WILMINGTON, DE 19899-0128
ATTORNEY FOR THE MAY DEPARTMENT STORES CO.
(302) 573-4800
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Case 1:04-cv—O1554-SLR Document 24 Filed O3/O9/2006 Page 2 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RENEE W. BYRD.
Plaintiff,
v. Civ. No. 04-1554-SLR
MAY DEPARTMENT STORES., CO.,
Defendant.
RESPONSE
lt simply appears that the May Departments Store (here after to be called
Strawbridge’s) did not applied their rule of zero percent tolerance of be physically
contacted (being hit, pushed, etc) when it comes to Laurie Ableman and white
female. I was employment by Strawbridge's for twenty—two years and was know
as a star employee, with many awards given for sales and customer service.
Laurie Ableman on the other had many negativelbad complaints in her file.
Why Laurie would be giving numerous chances, when my open mouth was
slammed into the back of a wooden chair and I did react back with frustration
when J.D. Fleischer was laughing. lt was a reaction on my part, while on the
other hand Laurie Ableman got out of her seat while on the phone to push me
with force, sending me to catch myself. Laurie by Strawbridge's had been given
many chances with many negative write ups. While, I reacted (and with a great
customer service record) got fired with one incident. Many managers and
employees can validate both Laurie and me.
I hope, this is what's needed in my response and I hope Laurie name is spelled
correctly.
lfuiil Renee W. Byrd, Plaintiff
Q ..·· < MARCH 7_ gggg
Iiliri — 0 2000
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Case 1 :04-cv—O1554-SLR Document 24 Filed O3/O9/2006 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RENEE W. BYRD
Plaintiff,
V. _ No.04—1554 (SLR)
Fi
THE MAY DEPARTMENT STORES CO.
Defendant,
CERTIFICATE OF SERVICE
I herby certify that on this 7th day of March 2006, caused to be placed in the United States i
Mail postage prepaid a true and correct copy of Plaintiff Renee W. Byrd Motion for
Summary Judgment, Plaintiff Renee W. Byrd’s Opening Brief in Support of its Motion
for Summary Judgment and Exhibits to Plaintiff Renee W. Byrd Opening Brief In
Support Of Its Motion for Summary Judgment for:
Daniel P. Bennett
Delaware Bar No. 2842
The Corporation Plaza
800 Delaware Avenue, Suite 200
P.O. Box 128 i
Wilmington, De 19899-0128
Attorney for The May Department Stores Co.
RENEE W. BYRD ,
PLAINTIFF
2334 TOLSTOY LANE
NEWARK, DE 19702
(302)834-2123
DATE: MARCH 7, 2006

Case 1 :04-cv—O1554-SLR Document 24 Filed O3/O9/2006 Page 4 of 4
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