EEOC v. Freeman

Filing 27

MOTION for Partial Summary Judgment by Freeman Responses due by 9/24/2010 (Attachments: # 1 Memorandum in Support of Motion for Partial Summary Judgment, # 2 Attachment A - Declaration of Suzanne Bragg with Exhibit 1 and Exhibit 2, # 3 Attachment B, # 4 Attachment C, # 5 Statement of Undisputed Facts in Support of Motion for Partial Summary Judgment)(Mirengoff, Paul)

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EEOC v. Freeman Doc. 27 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (SOUTHERN DIVISION) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v. FREEMAN, Defendant. DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT Pursuant to Fed R. Civ. P. 56(b), Defendant Freeman moves for summary judgment as to all claims in this lawsuit relating to decisions not to hire applicants based on criminal history that were made more than 300 days before the date on which Plaintiff EEOC notified Freeman it had expanded its investigation of this matter to include Freeman's use of criminal history information. As explained in the accompanying Memorandum of Law, challenges to these hiring decisions are time-barred. Respectfully submitted, AKIN GUMP STRAUSS HAUER & FELD LLP /s/ Donald R. Livingston Donald R. Livingston (Bar No. 15787) Paul E. Mirengoff (admitted pro hac vice) 1333 New Hampshire Avenue, N.W. Washington, D.C. 20036 Telephone: (202) 887-4000 Facsimile: (202) 887-4288 dlivingston@akingump.com pmirengoff@akingump.com Attorneys for Defendant Freeman Case No. 8:09-CV-02573-RWT Dockets.Justia.com CERTIFICATE OF SERVICE This is to certify that the undersigned caused to be served on September 7, 2010 the foregoing Defendant's Motion for Partial Summary Judgment, and the accompanying Memorandum of Law, via email and first class mail, postage prepaid, to the following: Debra M. Lawrence Ronald L. Phillips EEOC Baltimore Field Office City Crescent Building 10 South Howard Street, 3rd Floor Baltimore, MD 21201 /s/ Paul E. Mirengoff Paul E. Mirengoff 2

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