Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:03-cv-00149-WIG

Document 125

Filed 02/07/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FERRON SHORTER JR., Plaintiff, v. HARTFORD FINANCIAL SERVICES GROUP, INC., Defendant. : : : : : : : : : :

CASE NO. 3:02-cv-149(WIG)

FEBRUARY 7, 2005

PLAINTIFF'S MOTION FOR PRE- AND POST-JUDGMENT INTEREST AND EQUITABLE RELIEF Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, hereby moves for reinstatement, or, in the alternative, an award of front pay and benefits, pursuant to 42 U.S.C. § 2000e-5(g). In addition, Plaintiff seeks an award of pre- and post-judgment interest on the jury's award of back pay. Relevant Facts Following a five-day trial, the jury returned a verdict on January 28, 2005, in favor of the Plaintiff, Ferron Shorter Jr., on his claims of race and gender discrimination under Title VII of the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991, 42 U.S.C. § 2000e et seq., as well as on his claim of negligent infliction of emotional distress.1 The jury awarded Plaintiff $170,000.00 in back pay and benefits and $85,000.00 in general compensatory damages. Plaintiff now moves for reinstatement, or, in the alternative, front pay and benefits, pursuant to 42 U.S.C. § 2000e-5(g).2

The jury rendered verdicts in favor of Defendant on Plaintiff's claim of hostile work environment and intentional infliction of emotional distress. 2 Plaintiff's Amended Complaint requested equitable relief and such other relief as deemed appropriate by the Court. (doc. #35)

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ORAL ARGUMENT REQUESTED TESTIMONY REQUIRED

Case 3:03-cv-00149-WIG

Document 125

Filed 02/07/2005

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Reservation Plaintiff respectfully reserves the opportunity to file a memorandum with exhibits and affidavits in support of the instant motion by no later than the due date for Plaintiff's attorney's fees and costs motion.3 Despite due diligence in researching the due date for a post-judgment motion seeking equitable relief as described in the instant motion and pre- and post-judgment interest, Plaintiff has not ascertained an applicable deadline and therefore seeks to reserve his opportunity to file such a memorandum in support.4

PLAINTIFF FERRON SHORTER JR.

BY:

________________________ Rachel M. Baird (ct12131) Law Office of Rachel M. Baird 379 Prospect St Torrington CT 06790-5239 Tel: (860) 626-9991 Fax: (860) 626-9992

Local Civil Rule 11 provides: "Motions for attorneys' fees or sanctions shall be filed with the Clerk and served on opposing parties within 30 days of the entry of judgment. Any motions not complying with this rule shall be denied." 4 In the matter of Palma v. Pharmadica, 3:00-cv-1128(HBF), a jury verdict entered on November 28, 2002. Plaintiff filed a motion for award of front pay and benefits (doc. #104) on February 27, 2003, and a motion for pre-judgment and post-judgment interest (doc. #110) on March 21, 2003.

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Case 3:03-cv-00149-WIG

Document 125

Filed 02/07/2005

Page 3 of 3

CERTIFICATION I HEREBY CERTIFY that a copy of the foregoing was mailed first-class, postage paid to the following counsel of record on February 7, 2005: David L. Metzger, Esq. Metzger & Associates 25 Capitol Ave Hartford CT 06106 Margaret J. Strange, Esq. Jackson Lewis LLP 55 Farmington Ave Ste 1200 Hartford CT 06105

______________________________ Rachel M. Baird

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