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

Case 1:04-cv-01462-KAJ

Document 39

Filed 08/05/2005

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE APRIL BAYLIS, : : Plaintiff, : : v. : : RED LION GROUP, INC., a corporation of : the State of Pennsylvania, : : Defendant. :

C. A. No. 04-1462-KAJ

DEFENDANT RED LION GROUP, INC.'S MOTION FOR SUMMARY JUDGMENT Defendant, Red Lion Group, Inc. ("Red Lion"), by and through its attorneys, respectfully moves this Honorable Court for an Order granting its Motion for Summary Judgment. In support of its motion, Defendant submits its Opening Brief in Support of its Motion for Summary Judgment with accompanying Exhibits and Appendix. The

Accompanying Exhibits and Appendix have been filed contemporaneously with this motion. Defendant respectfully requests that the Court grant summary judgment in Defendant's favor on all counts asserted by Plaintiff against it.

/s/ Norman H. Brooks, Jr. Norman H. Brooks, Jr., Esquire (No. 2568) Marks, O'Neill, O'Brien & Courtney, P.C. 913 North Market Street, #800 Wilmington, DE 19801 (302) 658-6538 Attorney for Defendant DATED: August 5, 2005
DE044025.1