Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:08-cv-00011-GIVIS Document 12 Filed 12/06/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DIS'I`RICT OF PENNSYLVANIA
ARONDA D. BROOKINS
Plaintiffs, November I2. 2007
V.
RED CLAY CONSOLIDATED SCIIOOL DISTRICT
Defendant.
C.A. N. 07-3374
PLAINTIFES RESPONSE AND DISAGREEIVIENT TO
DEEEND/\NT’S. IVIOTION TO DISMISS EOR
IIVIPROPER VENUE
On September 4. 2007 I filed a complaint against Red Clay
Consolidated School District with respect to an improper
employment termination and violation of my civil rights
due to my criminal background. which is I7 V3 years old.
I am in disagreement with the deI`endant`s motion to
dismiss my case and I offer the following:
I. I was successfully employed with Red Clay from
1995-1999 and resigned in good standing after the
tragic death of my mother and husband six months
apart.
2. I was re-hired by Red Clay in September ot`2005 in the
Human Resources Department as a floating clerk with
the same criminal background I was hired with in l995.
I received a favorable evaluation upon completion of
their probationary »ir’ period.

Case 1:08-cv-00011-GIVIS Document 12 Filed 12/06/2007 Page 2 of 4
3. On or about March 8, 2006 I was covering for an absent
secretary in a school when I received a hand delivered
inter-office letter from Ms. Debra Davenport that I was
to meet with her in her office on March 10, 2006 and
advised to have union representation attend the meeting
with me. Unfortunately, the Union Representation was
out of town after asking for the 48-hour extension as
noted in our Union Contract. (See attached) Ms.
Davenport denied me the extension and terminated me
by mail for an unfavorable criminal background after
six months of successful employment.
4. I went to Delaware Labor Law Department to seek help
for what I felt is wrongful termination and was directed
to the US Equal Employment Opportunity Commission
(EEOC) located in Philadelphia Pennsylvania. I
received a final right to sue letter from the EEOC
indicating that I may file suit in a United States Federal
District Court and the closest US Federal District Court
to my residing in Delaware is the Federal Court located
in Philadelphia Pennsylvania.
5. Finally, I presently cannot afford an attorney to help me
with my case. However, I am certain that I was
wrongfully terminated from Red Clay School District
for a criminal history that I had been hired with back in
1995 and worked until 1999. Then, re-hired with the
same criminal history again in September 2005 until
being stripped of my civil rights in March 2006 for
something Red Clay was already aware of I was not

Case 1:08-cv-00011-GIVIS Document 12 Filed 12/06/2007 Page 3 of 4
aware that filing suit in US Federal Court in
Pennsylvania was wrong. I simply followed directions
from professional people who I felt was leading me in
the right direction. When I first contacted the Federal
Court in Pennsylvania, I was informed I could file there
and proceeded to do so.
6. Remedy Sought: Reinstated to a position with back pay
In conclusion, for the above stated reasons, I
as e e e e as P P Arendal). Broekins (Plaintiff) pleadewithetrreeeeteeeee ccscsc or scsssc
court to not dismiss my claims against Red Clay
for improper venue.
cc: Judge Katz
Jolm D. Balaguer
(Attorney for Red Clay Consolidated School
District)

Case 1:08-cv-00011-GIVIS Document 12 Filed 12/06/2007 Page 4 of 4
ARONDA D. BROOKINS, C.A. NO 07-3374
(Plaintiff)
V.
RED CLAY CONSOLIDATED
SCHOOL DISTRICT (Defendant.)
CERTIFICATE OF SERVICE
I Aronda D. Brookins Pro se do hereby certify that on
this 4"‘ day of December, 2007 two copies of the
foregoing Plaintiffs Response And Disagreement To
Defendant’s Motion to Dismiss For Improper Venue are
mailed U.S. First Class Mail, postage prepaid to the
Honorable Judge Katz and the defendant’s Attorney
John D. Balaguer
Aronda D. Brookins
l08 Chestnut Ave apt #2
Wilmington, DE l9805

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