Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:00-cv-01115-PCD Document 86-2 Filed O2/14/2006 Page 1 of 4
EXHIBIT A

C - - - -
ase 3.00 cv 01115 PCD Document 86-2 Filed 02/14/2006 Page 2 of 4
::,1 - ttf
STATE OF CONNECTICUT
` COMMISSION ON H UAMN R1 GH T S AND OPPORTUNITIES
CAPITOL REGION OFFICE
1229 ALBANY AVENUE HARTFORD, CT 06112
. TEL. (860) 566-7710 FAX (860) 566-1997
Certified N0. Z 158 650 594
September 5, 2000 = ·
srv ~—920U0 Q
Suzanne M. Searles i
39 Old Farms Crossing ‘ I
Avon, CT 06061 . - g
RE: NOTICE OF FINAL AGENCY ACTION
Case Name: Suzanne M. Searles v. West Hartford Board of Education
CHRO No.: ,0010385
EEOC No.: 1621201203
Dear Ms. Searlesz
Notice is hereby given that pursuant to Section 46a-83(b) of C.G.S, the Commission has processed
your complaint through its Merit Assessment processes.
Further, you are hereby notiiied that as a result of these activities, your complaint has been dismissed
for the reason that there is no reasonable possibility that further investigation will result in a finding
of reasonable cause.
That is, a review of the case tile is not likely to reveal that you were retalliated against by the
respondent in the form of failure to rehire on the basis of your previous opposition of respondent’s
alleged discriminatory practice(s) in violation of Connecticut General Statute §46a—60(a)(4). Rather,
the facts are more likely to show that respondent did not subject you to any form of adverse
treatment on the basis of your membership in a protected class, such based upon the supporting
documentation submitted by the respondent, the remoteness in time between the alleged adverse
action and your participation in a civil rights proceeding, and finally, by the lack of information in
the case tile which would serve to establish a nexus between the two incidents Ge. the failure to hire
and your tiling of previous discrimination cornplaint(s)). _; ~
While a review of your complaint affidavit reveals that you have alleged a series of other
discriminatory acts allegedly engaged in by the respondent (eg. termination, demotion, and
suspension), these incidents are not timely pursuant to Qbnn. Qian. Stat. §46a-82(e) in that they were
` not tiled within 180 days of their respective occurrences as mandated by the aforementioned statute.

A Case 3.00-cv-01115-PCD Document 86-2 Filed O2/14/2006 Page 3 of 4
As such, a final review of the ease file is not lilcely to show that respondent subjected you to any
adverse treatment on the basis of your membership in a protected class. Therefore, there exists no
reasonable possibility that further investigation of your complaint will result in a finding of
reasonable cause. Finally, because you did not provide additional information likely to show that
respondent’s reason is false or pretextual, there are insufficient grounds upon which to base a
conclusion that this complaint should be retained for hirther processing.
The complainant may apply for reconsideration, requesting that the Commission reconsider its
decision dismissing the complaint, as provided in subsection (b) of Section 46a—83 of the C.G.S.
(formerly Public Act 94-23 8). The reconsideration request must be in writing and ined at the
~ Commission's administrative ofiice stated on the letterhead within fifteen {15) calendar days from
the date of this letter. It is the complainants responsibility to file a timely request. No additional
information after this fifteen (l5)'day period will begonsideredn llntirnely r_e__quests will not be
gnsidered. The request should state specifically the grounds upon which the application is based.
Generally, no new documentation or evidence can be considered as only documentation in the case
tile at the time of dismissal will be reviewed. Any request for reconsideration must be submitted
to the regional office listed on the letterhead.
A copy of your request for reconsideration must be mailed to the respondent and respondents
attorney, if any, at the address listed at the bottom of this letter. You should certify that you have
done so in your request for reconsideration Bled with the Commission. If you do not request
reconsideration of the dismissal of your complaint, you will be issued a release of jurisdiction
which grants you the right to file a civil action in Superior Court.
The complainant may appeal this disposition to the Superior Court of the State of Connecticut if
reconsideration ofthe dismissal is requested and denied. Any appeal must strictly comply with all
of the applicable statutory procedures, requirements, and time frames. You may wish to consult an
attorney regarding the proper tiling of an administrative appeal.
Sincerely, { A ,___ __ _
c>/1/·-$3 Q»=#—· " "
Ep ani 'Carrasquillo
Regional Manager
cc: Elizabeth Dee Bailey, Assistant Corporation Counsel
Town of West Hartford L i
50 South Main Street .- ,
West Hartford, CT 06107-2431
Certified No. Z 158 599

— C 3:0 - - -
N ase 0 cv 01115 PCD Document 86-2 Filed O2/14/2006 Page 4 of 4 E
Attorney James M. Seonzo
Halloran & Sage, LLP
One Goodwin Square
Hartford, CT 06103-4303