Free Answer to Complaint - District Court of Delaware - Delaware

Case 1:05-cv-00015-SLR

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Filed 05/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE STEPHANIE F. HAYGOOD Plaintiff, v. BARRY CONNORS, LINDA HARE TUCKER, KEN KOON AND SHEILA FERRARO Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 05-00015-SLR

DEFENDANTS' ANSWER TO COMPLAINT

1. 2.

This allegation asserts the jurisdictional requirements. No response is required. After reasonable investigation, answering defendants have insufficient

information to form a belief as to the truth of the allegations in this paragraph. 3. 4. 5. 6. Denied as stated. Denied. Denied. Defendants' deny any and all alleged discriminatory practices. It is admitted that

Ms. Haygood's employment with Woodbridge School District was terminated effective June 30, 2003. 7. It is admitted that plaintiff filed charges with the Department of Labor of the Sate

of Delaware. The Department of Labor investigated plaintiff's charges and dismissed them. 8. It is admitted that plaintiff filed charges with the Equal Employment Opportunity

Commission of the United States. The EEOC adopted the findings of the Delaware Department of Labor and dismissed the charges.

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Case 1:05-cv-00015-SLR

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9.

It is admitted that the Equal Employment Opportunity Commission issued a

Notice-of-Right-to-Sue letter to plaintiff on November 1, 2003. 10. 11. 12. Defendants' deny any and all alleged discriminatory acts. Defendants' deny any and all alleged discriminatory acts. Denied. A copy of the charges filed with the Delaware Department of Labor

and/or the EEOC was not attached to this Complaint. 13. 14. Denied. Denied.

FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint fails to state a claim upon which relief may be granted.

WHEREFORE, answering defendants demand judgment in their favor and against the plaintiff, including costs of this suit.

WHITE AND WILLIAMS LLP

NATALIE L. PALLADINO (ID# 3878) 824 N. Market Street, Suite 902 P.O. Box 709 Wilmington, DE 19899-0709 (302) 467-4531 Attorney for Defendants, Barry Connors, Linda Hare Tucker, Ken Koon and Sheila Ferraro Dated: May 23, 2005

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Case 1:05-cv-00015-SLR

Document 13

Filed 05/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE STEPHANIE F. HAYGOOD Plaintiff, v. BARRY CONNORS, LINDA HARE TUCKER, KEN KOON AND SHEILA FERRARO Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 05-00015-SLR

CERTIFICATE OF SERVICE

I, Natalie L. Palladino, Esquire, do hereby certify that on this 23rd day of May, 2005, two copies of the above foregoing DEFENDANTS' ANSWER TO COMPLAINT were served upon the following via e- filing and/or first class mail, postage prepaid: Stephanie F. Haygood RD 2 Box 6-1 Selbyville, Delaware 19975 WHITE AND WILLIAMS LLP

NATALIE L. PALLADINO (ID # 3878) 824 Market Street, Suite 902 P.O. Box 709 Wilmington, DE 19899 (302) 654-0424 Attorney for Defendants, Barry Connors, Linda Hare Tucker, Ken Koon and Sheila Ferraro

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