Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1 :04-cv—00943-KAJ Document 60 Filed 02/17/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT i.§§;j$"1ti£.t-Chit: tif"ii`iL"tLt;.?{1%:2. in
FOR THE DISTRICT OF DELAWARE , N {_ K __
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DINO G. PETROCELLI, )
)
Plaintiff, )
)
Vs. )
) Case No. 04-CV—943-KAJ
DAIMLERCHRYSLER CORPORATION, )
)
Defendant, )
)
PLAINTIFF DINO G. PETROCELLPS RESPONSE
TO DEFENDANT DAIMLERCHRYSLER CORPORATION’S
MOTION FOR SUMMARY JU DGEMENT
1, Dino Petrocelli, the plaintiff in afore mentioned case, pray that the court
will allow proceedings to continue as planned. Defendant has continually attempted to
stall the process since plaintiff tiled charge originally and would not cooperate with
investigations or refused to answer to any attempts to resolve the matter at hand. Only
after plaintiffs request from the couxt to find the defendant in default, was there a
response on behalf of defendant to cooperate with the plaintiff. Cooperation from the
defendant at mediation was also limited, leaving the courl; no option at all but to cancel
mediation process, again leaving matters unresolved. The motion for summary judgement
is an attempt by the defendant to deny just treatment in behalf of the plaintiffs case, for
the harsh work environment and derogatory treatment inflicted upon plaintiff during a
majority of plaintiffs employment at DaimlerChrysler from May 19, 1997 to January 11,
2001.The defendant can not disprove any of the plaintiffs charges against defendant and
can only attempt to preclude any fair conciliation in aforementioned case by motion for
summary judgement. Since originally tiling charge of discrimination against defendant,

Case 1:04-cv-00943-KAJ Document 60 Filed O2/17/2006 Page 2 of 3
plaintiff has cooperated with defendant in all investigation. Plaintiff only wants the
opportunity to present case against defendant in good faith and come to a reasonable
resolution.
Wherefore Plaintiff Dino G. Petrocelli respectfully request that the court deny
defendant motion for summary judgement and allow scheduled case hearing process
COl'11f1I'11.1C E15 p1ElI']l'l€Cl.
Dino Petrocelli
129 Emery court
Newark, DE 19711
(3 O2)894- 1496
Dated 1 November 17, 2006

Case 1:04-cv—OO943-KAJ Document 60 Filed O2/17/2006 Page 3 ot 3
CERTIFICATE OF SERVICE
I, Dino G. Petrocelli, certify that on this 17th day of November, 2005, that foregoing
PLAINTIFF DINO G PETROCELLI ‘S RESPONSE TO DEFENDANT
DAIMLERCHRYSLER CORPORATION’S MOTION FOR SUMMARY
JUDGEMENT was filed with U.S District Court District of Delaware per docket and
one true and correct copy was mailed via FIRST CLASS U.S. MAIL CERTIFIED,
POSTAGE PAID on the following:
Jennifer Gimler Brady (Del. 2874)
Sarah E. DiLuzio (Del. 4085)
Hercules Plaza, Sixth Floor
1313 North Market St.
P.O. Box 951
Wilm. DE 19899
(302) 984-6000
s W
Dino G. Petrocelli
129 Emery Court
Newark, DE 19711
(302)894-1496