EQUAL EMPLOYMENT OPPORTUNITY COMMISSION ADMINISTRATIVE COURT

You are notified that on _______________ (date), at ______ (time), or as soon thereafter as the Complainant can be heard, at the Equal Employment Opportunity Commission Administrative Court at _______________________________________________________ (address).

The Complainant will bring on for hearing her Motion for Summary Judgment for the reasons stated in the attached Motion.

Respectfully Submitted,

___________________________________

Melody J. Rodgers

2248 Kay Road

Greenville, NC 27858

Insert Phone Number

Insert Email

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION  ADMINISTRATIVE COURT

NOW COMES Melody J. Rodgers before this Honorable Court, and brings this Motion for Summary Judgment. In support of this Motion for Summary Judgment, Complainant avers before this Honorable Court as follows:

1. Rule 56 of the Federal Rules of Civil Procedure stipulates that: “A party may move for summary judgment, identifying each claim or defense – or the part of each claim or defense – on which summary judgment is sought. The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. The court should state on the record the reasons for granting or denying the motion.”
2. Complainant initiated this suit against Defendant for wrongful termination. 
3. Complainant filed her Answers to Interrogatories and Requests for Production of Documents (the “Answer”) pursuant to an Order issued by this Court on 02/22/2021.
4. To date, Defendant has not provided any discovery or evidence to refute Complainant’s Answer filed on Insert Date.
5. There is no genuine dispute by Defendant as to any material fact. If there was any dispute, Defendant would have provided discovery or evidence to refute Complainant’s Answer.
6. Plaintiff is entitled to judgment as a matter of law.
7. In Celotex Corp. v. Catrett, 477 US 317, the United States Supreme Court held thus: “Under Rule 56(c), summary judgment is proper if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. In our view, the plain language of Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial. In such a situation, there can be no genuine issue as to any material fact since a complete failure of proof concerning an essential element of the nonmoving party’s case with respect to which she has the burden of proof.”
8. While citing Anderson v. Liberty Lobby, Inc., ante, at 250 in Celotex Corp., the United States Supreme Court also stated that the standard for granting summary judgment mirrors the standard for a directed verdict under Federal Rule of Civil Procedure 56(a).

REASONS WHEREFORE, Complainant respectfully requests this Honorable Court to grant her the following reliefs:

1. Grant this Motion for Summary Judgment;
2. Award Complainant punitive, back pay, front pay and compensatory damages in the sum of $250,000;
3. Award Complainant such equitable relief as may be appropriate under the circumstances; and
4. Award Complainant such further relief as this Honorable Court deems necessary and proper.

Dated:

Respectfully Submitted,

___________________________________

Melody J. Rodgers

2248 Kay Road

Greenville, NC 27858

Insert Phone Number

Insert Email

VERIFICATION

I, Melody J. Rodgers, being duly sworn depose and say that I am the Complainant in the above entitled action, that I have read the foregoing Motion for Summary Judgment and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.

_________________________________

(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this the _____ day of ____________________, 2021.

______________________________

Notary Public

________________________________________

(Printed name of Notary Public)

My Commission Expires: ____________________

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was sent on the (Date) day of (Month) (Year) by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to the following parties or attorneys of record:

(Name of Attorney), Attorney at Law

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