Free Status Report - District Court of Delaware - Delaware

Case 1:07-cv-00813-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

BRIE DREW, Plaintiff, v. CORPORATION SERVICE CO., INC. a Delaware corporation,

Defendant.

§ § § § § § § § § § §

C.A. No. 07-813 GMS

FED. R. CIV. P. 26(f) JOINT STATUS REPORT COME NOW, Brie Drew ("Plaintiff") and Corporation Service Co., Inc. ("CSC" or "Defendant")(collectively the "Parties"), pursuant to Federal Rule of Civil Procedure 26(f), with this Joint Status Report to the Court and state as follows: 1. Jurisdiction: Jurisdiction properly lies with this Court pursuant to Title

VII of the Civil Rights Act of 1963 ("Title VII"), 42 U.S.C. § 1981, and 28 U.S.C. §1331. 2. 3. Jury or Non-Jury: The Plaintiff has filed a demand for a jury trial. Judicial Availability: If the Court believes that the use of a Magistrate

Judge in this matter would be beneficial, the Parties do not object. 4. 5. Venue: Venue properly lies with this Court. Statement of the Case: Plaintiff contends that Defendant terminated her

employment because of her race, retaliated against her because of her alleged complaints of racial discrimination, and subjected her to harsher treatment than similarly situated non-African American employees, in violation of Title VII and 42 U.S.C. § 1981. Defendant contends that Plaintiff's termination was based on legitimate, nondiscriminatory reasons, namely her poor performance and the use of profane and abusive
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language toward a manager, a terminable offense pursuant to CSC's Employee Handbook, and not because of her race. 6. 7. Pendent State Claims: This case does not include pendent state claims. Joinder of Parties & Amendment of Pleadings: The parties do not

anticipate filing any motions for joinder of additional parties or for amendment of the pleadings. 8. Disclosures & Exchanges: The parties intend to make the initial

disclosures required under Fed. R. Civ. Pro. 26(a)(1) within 60 days from the date of their joint status conference, held on January 25, 2008. 9. Discovery: The parties anticipate requiring 150 days to complete

discovery in this matter. The number of depositions required by the parties will be likely be no more than five (5). The parties do not anticipate that any deposition will exceed one day (seven hours) in length. 10. Motions: Plaintiff may file a motion for summary judgment at or near the

completion of discovery. Defendant may also file a motion for summary judgment prior to or after the completion of discovery. 11. Alternative Dispute Resolution: The parties are open to the possibility

of some form of ADR upon the completion of reasonable discovery. 12. Length of Trial: The parties estimate the trial of this matter will last

approximately three days (one and one-half days each). 13. Prospects of Settlement: Counsel for the parties have had preliminary The parties do not presently

discussions concerning the possibility of settlement.

anticipate an early settlement, but they will keep the lines of communication open toward the possibility of settlement. 14. Other: There are no other pertinent matters at this time.

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DATED this 28th day of March, 2008.

Respectfully submitted,

LAW OFFICE OF JOHN M. LAROSA

/s/ John M. LaRosa John M. LaRosa (DE Bar No. 4275) Two East 7th Street, Suite 302 Wilmington, DE 19801-3707 (302)888-1290 [email protected] and Sean Galvin, Esq. KARPF, KARPF & VIRANT 3070 Bristol Pike Bldg. 2, Suite 231 Bensalem, PA 19020 (215)639-0801 Counsel for Plaintiff

March 28, 2008 Date

McCARTER & ENGLISH, LLP

/s/ Christopher A. Selzer Michael P. Kelly (DE Bar No. 2295) Christopher A. Selzer (DE Bar No. 4305) Renaissance Centre 405 N. King Street, 8th Floor P.O. Box 111 Wilmington, DE 19801 (302)984-6300 [email protected] [email protected] and

March 28, 2008 Date

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Sarah E. Bouchard, Esq. Tara Patterson Hammons, Esq. MORGAN LEWIS & BOCKIUS, LLP 1701 Market Street Philadelphia, PA 19103-2921 (215)963-5000 Counsel for Defendant

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