Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:03-cv-01050-DJS

Document 29

Filed 08/16/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARY SAROJAK PLAINTIFF, V. CIVIL ACTION NO. 3:03CV1050 (DJS)

THE METALLICS GROUP D/B/A METALLICS, INC. and F. MICHAEL MOLA AUGUST 13, 2004 DEFENDANTS. MOTION FOR SUMMARY JUDGMENT Pursuant to Rule 56 of the Federal Rules of Civil and Local Procedure, the Defendants, Metallics, Inc. and F. Michael Mola, moves for summary judgment on all eight (8) counts of the Amended Complaint filed by the Plaintiff, Mary Sarojak, in the above-captioned matter. In the First, Second, Third and Fourth Counts, the Plaintiff alleges that the Defendant Metallics sexually harassed and retaliated against her in violation of Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. Section 2000e et seq.) and the Connecticut Fair Employment Practices Act (Connecticut General Statutes Section 46a60 et seq.). In the Fifth and Sixth Counts, the Plaintiff alleges intentional and negligent infliction of emotional distress by the Defendant Metallics. In the Seventh Count, the ORAL ARGUMENT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01050-DJS

Document 29

Filed 08/16/2004

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Plaintiff alleges breach of contract. Lastly, in the Eighth Count, the Plaintiff alleges breach of the covenant of good faith and fair dealing. The Plaintiff cannot, as a matter of law, demonstrate a genuine issue of material fact as to any of her claims set forth in the Amended Complaint.

The Defendants have attached a Local Rule 9(c)(1) Statement of Undisputed Facts and a Memorandum of Law in Support of Motion for Summary Judgment with accompanying exhibits in support of this motion Wherefore, the Defendant respectfully requests that the Court grant its Motion for Summary Judgment. THE DEFENDANT, THE METALLICS GROUP D/B/A METALLICS, INC. AND F. MICHAEL MOLA

_____________________________ William A. Ryan (ct 15530) Holly Quackenbush Darin (ct10183) Ryan & Ryan, LLC 900 Chapel Street, Suite 621 New Haven, CT 06510 (203) 752-9794 -Its Attorneys-

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Case 3:03-cv-01050-DJS

Document 29

Filed 08/16/2004

Page 3 of 3

CERTIFICATION The undersigned hereby certifies that the foregoing was mailed, first class, postage prepaid, this 13TH day of August 2004 to all counsel and pro se parties of record as listed below: Fred Frangie Robert Fortgang Associates 573 Hopmeadow Street Simsbury, Connecticut 06070

_______________________ William A. Ryan

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