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Civil Rights: Jobs | New York Western
Leave to File Document
MOTION for Leave to File an Inadvertently Omitted Exhibit to Plaintiffs Opposition to Defendants Motion for Summary Judgment, and for an Extension of Time Nunc Pro Tunc Pursuant to Federal Rule of Civil Procedure 6(b)(1)(B) by Russell J. DeFranco. (Attachments: # 1 Declaration of Kevin P. Wicka, Esq., # 2 Exhibit A- Exhibit XX in the Appendix to Plaintiffs Local Rule 56.1 Counterstatement of Material Facts and Responses to Defendants Local Rule 56.1 Statement, # 3 Exhibit B- Wicka email, # 4 Exhibit C - Torcello email, # 5 Memorandum in Support)(Wicka, Kevin)
Response in Opposition to Motion
RESPONSE in Opposition re 53 MOTION for Summary Judgment filed by Russell J. DeFranco. (Attachments: # 1 Declaration of Kevin P. Wicka, Esq., # 2 Declaration of Russell DeFranco, # 3 Statement of Undisputed Facts Rule 56 Contested Facts, # 4 Appendix to Rule 56 Contested Facts, # 5 Exhibit A - DeFranco Transcript Excerpts, # 6 Exhibit B- Smith Transcript Excerpts, # 7 Exhibit C- Sinatra Transcript Excerpts, # 8 Exhibit D- Pollack Transcript Excerpts, # 9 Exhibit E- Termination Justification, # 10 Exhibit F- Ethics and Compliance Program, # 11 Exhibit G- Draft Investigation Report, # 12 Exhibit H- Email correspondence between Smith and DeFranco, # 13 Exhibit I - Email correspondence Smith, # 14 Exhibit J- 2017 Annual Performance Review, # 15 Exhibit K- Ethics and Compliance Employee Hotline, # 16 Exhibit L -Email correspondence from Russell DeFranco to Sean Smith, # 17 Exhibit M- EMERGENCYONE History and Physical Form, # 18 Exhibit N- Email correspondence between Ryan Sinatra and Sean Smith,, # 19 Exhibit O-Email correspondence from Ryan Sinatra, Sean Smith and Rani Pollack, # 20 Exhibit P-Email correspondence between Ryan Sinatra and Sean Smith, forwarded to Rani Pollack, # 21 Exhibit Q- Letter from the Office of Inspector General to NYPA, # 22 Exhibit R-Email correspondence between Sean Smith and Rani Pollack, # 23 Exhibit S-RECORD OF DISCIPLINE Written Warning, # 953 additional result(s)
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