Free Trial Memo - District Court of Connecticut - Connecticut

I . Case 3:00-cv—00656-SRU Document 120 Filed 09/1 /2004 Page 1 of 3
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UNI'I`ED STATES DISTRICT COU T I" I IZ. D I
DISTRICT OF CONNECTICUT
MARSHALL CHAMBERS, ) I ZIIIIII SEP I I I
V Plaintiff I CIVIL No. 3:00C I I; I ;_ I I
I ) ISRIIBIEI .L1_ II€E.‘IL‘I I.;
ANTHONY PRINCIPI, Secretary, ) I
U.S. Department of Veterans Affairs, ) DATE: Septembe 13, 2004 I I
Defendant. )
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PLAINTIFF’S SUPPLEMENTARY PRETRIAL S BMISSION Q
In addition to all those witnesses listed in the Plaintiffs SupIlementary Pretrial I I
Memorandum dated March 25, 2004, Plaintiff may call the f llowing witnesses: I I
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1. Paul Stepanovich, Ph.D. I
Associate Professor
School of Management I .
Southern Connecticut State University I I
501 Crescent Street
New Haven, CT 06511 I I
2. Norman Gehrline, Ph.D. I
Blind Rehabilitation Center
VA Medical Center I I
950 Campbell Avenue I I
West Haven, CT 06516 I
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3. Christine Covington I I
EEO Officer or the Keeper of Records I
VA Medical Center I
950 Campbell Avenue I
West Haven, CT 06516 I I
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4. Delma I·Iasl Keeper of Records I
Department of Veterans Affairs
Office of Resolution Management (08M) I I
200 Springs Road I
Bedford, MA 0170 I
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t ' Case 3:00-cv-0065@RU Document 120 Filed 09/ " 2004 Page 2 of 3 N
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As to Plaintiff's Exhibits, Plaintiff will offer all those exhibit listed in Plaintiff’s N
Supplementary Disclosure dated March 25, 2004 and desig ated with an asterisk. N
i.e. Exhibits 1.0001 ("Plaintiffs Appointment to VA Medical l enter") through N
8.002 ("Collective Bargaining Agreement,. . ")and 13.000 ("E V ployment lob
Searches").
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In addition, Plaintiff reserves the right to offer any exhibits, hich are factually
relevant and material to the Plaintiffs claims that the Defen ant failed to l
promote the Plaintiff based. on his race, gender and religion. These may also
include, but are not limited. to other exhibits the Defendant 1 ay consider to be
evidence of retaliation. Nowhere in the history of Plaintiff's mployment with the
Defendant did the employer document anywhere the allege deficiencies in the
Plaintiff's performance prior to the Defendant's failure to pr mote. Such exhibits l
will thus not be offered for the purposes of supporting a clai of retaliation but N
to invalidate the reasons proffered by the Defendant for den. ing the Plaintiff
promotion and to show that the latter reasons were pretextu l. A .
More specifically, Plaintiff will also seek to introduce a repo t by the Defendant N
(e.g., VA Office of Equal Opportunity; VA's ORM) which ad its that during the
period Plaintiff was employed by the Defendant blacks were more likely to be "
the victims of discrimination regardless of education, profes ion or grade. N
Defendant has proposed and Plaintiff has agreed that Defen ant will incorporate
the foregoing into the Parties' Ioint Pretrial Memorandum. N
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- Case 3;00—cv—0O65F5§RU Document 120 Filed O9/Q }2004 Page 3 of 3 I I
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. THE PLAINTIFF I
MARSHALL CHAI BERS
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ALEB M. PILG I , Esq. I I
Law Offices of Ca eb M. Pilgrim, LLC
1404 Wha§I1ey Ave ue - 2nd Floor
New I-Iaven, CT 06 10 I I
Tel: 203-387-2524 I I
Federal Bar No. ct 4857 I I
CERTIFICATION
This is to certify that a copy of the foregoing was faxed and ailed, postage
prepaid, this 13***. day of September 2004 to Attorney Laure Nash, AUSA, US I
DO] 157 Church Street, New Have , T 6510. #’"“"` > I
_¢=;Zc.v€¤·¤. ‘,»._, .
CALEB M. PILGI M, Esq. I I
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