Free Motion to Stay - District Court of Connecticut - Connecticut

_ Case 3:00-cv-006585SRU Document 88 Filed O3€5_(%2004 Page 1 of 2 I
UNITED STATES DISTRICT COURT I
DISTRICT OF CONNECTICUT F E L, E D

MARSHALL CHAMBERS, } mm! MAH 30 A H: BI I
Plaintiff } Docket No.: 3:0q[)g{Q)(p )JRT ,
V- } BRIUGEPORT. CONN I
} I
Defendant-ANTHONY J. PRINCIPI } I
Secretary, U.S. Department of } I
Veterans Affairs, } March 28, 2004 I
Defendant . }
MOTION FOR STAY PENDING INTERLOCUTORY APPEAL
Plaintiff, MARSHALL CHAMBERS, hereby moves this Court for a stay of I
litigation pending interlocutory appeal. In support of this motion, Plaintiff I
represents as follows: I
(1) Plaintiff, Marshall Chambers, has prepared, and will shortly file,
I
pro se, a Petition for Interlocutory Appeal in the above-
captioned matter. I
(2) Fairly read, the evidence in this case demonstrates that the I
Plaintiff should ultimately prevail on the merits of his I
retaliation claims, his failure to promote claim, and his
demotion claims. These issues are separate and distinct from
the amount of any recovery.
I
(3) Plaintiff will be irreparably injured absent a stay, since this
matter involves in particular the disposition of eight specific
retaliation claims, and in the absence of a stay will require re-
litigation of those claims.
1
-1%+ _%_T`T`T_v—v ·l -·- —e Y as I l.ll ;..FQQ.l l lllll llPlPSFl lFF C

(_ ‘ Case 3:00-cv-006/565SRU Document 88 Filed 03{8OI2004 Page 2 of 2
(4) The other party in this case is the Federal Government. Plaintiff I
Chambers is an currently unemployed veteran. Given the
inherent inequality of resources, the equities in this matter tilt
squarely in favor of the Plaintiff. The issuance of a stay will not
substantially injure the Federal Government, the other party
interested in these proceedings. There is a far greater likelihood I
of prejudice to the Plaintiff' s legal rights in this case.
(5) Finally, the public interest lies in a clear, comprehensive, speedy I
resolution of all those issues, including the specific retaliations I
claims raised by the Plaintifli and a fair, reasonable and
equitable disposition, thereof. I
I
WHEREFORE: Plaintiff respectfully moves this Court for an Order staying all `
proceedings pending Interlocutory Appeal.
THE PLAINTIFF,
0 I
·»=-e/e¤e—m${‘v xs Per
CALEB M. PILGRI , Esq.
1404 Whalley Avenue I
New Haven, CT 06515 j
Tel: 203-387-2524
Fed.Bar # ct 14857 ¤
CERTIFICATE
This is to certify that a copy of the foregoing was forwarded postage pre-paid to
Lauren M. Nash, Esq., to 157 Church Street/P.O. Box 1824, New Haven CT
06508; this 28"T day of March, 2004. / ’”"` >
7 ie?/¤?·*€')’!»Tj,% cn.
C/-\LE“B M. PILGRIM, Esq.
2 i
I