Free Response to Motion - District Court of Delaware - Delaware

Case 1 :04-cv-01462-KAJ Document 42 Filed 08/30/2005 Page 1 of 1
IN THE DISTRICT COURT
C FOR THE DISTRICT OF DELAWARE
APRIL BAYLIS, : .
Pmmirr E
v. I C. A. No. 04-1462-KAJ
RED LION GROUP, INC., a corporation
ofthe State of Pennsylvania, :
Defendant. ·
PLAINTIFF'S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT C
Plaintiff, April Baylis, by and through her attorneys, respectfully asks this
Honorable Court for an Order denying Defendant, Red LionGroup, Inc.’s Motion for
A Summary Judgment. In support of this motion, Plaintiff submits its Reply Brief in
Support of her request to deny Defendant’s Motion for Summary Judgment with
accompanying Exhibits and Appendix. The Accompanying Exhibits and Appendix have
been filed contemporaneously with this motion. p y
Plaintiff respectfully requests the Court to deny Defendant’s Motion for Summary
Judgment on all counts. I
The Law Offices of Bayard Marin
. 521 West Street
` Wilmington, DE 19801
302-658-4200
· Attorney for Plaintiff
Dated: August 30, 2005