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Compare And Contrast The Lewis And Clark Expedition

Department of Transportation, Defendant.

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Civil Action No. May 20, Brown, Gary T. Michelle Lo, U. Department of Transportation. Glass asserts two basic claims in this action: a first, she contends that the NHTSA discriminated against her on the basis of her race and visit web page when she was not Com;are for a competitive position in or about June or EExpedition the "Non-Selection Claim" ; and b second, she contends that the NHTSA discriminated against her on the basis of her race, and retaliated against her for participating in protected activity, when she was denied a promotion in October the "Failure-to-Promote Claim".

The United States District Court for the District of Columbia has supplemented Rule 56 of the Federal Rules of Civil Procedure with Local Civil Rule 7 h 1which requires that each party submitting a motion for summary judgment attach a statement of material facts for which that party contends there is no genuine dispute.

Compare And Contrast The Lewis And Clark Expedition

The party opposing the motion Expedigion, in turn, submit a responsive statement enumerating all material facts that the party contends are genuinely disputed. See LCvR 7 h 1. Both the moving party's initial statement and the opposing party's responsive statement must be based on "references to the parts of the record relied on to support the statement. Click well-reasoned rule "places the burden on the parties and their counsel, who are most familiar with the litigation and the record, to crystallize for the district court the material facts and relevant portions of the record.

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As the parties in this case have been cautioned on multiple occasions, this Court strictly adheres to the dictates of Local Civil Rule 7 h 1 when resolving motions for summary judgment. Scheduling Order Oct. Glass has submitted a responsive statement responding to each of the factual statements set forth in the NHTSA's statement, and has identified a number of additional factual allegations which she contends support her claims, but her submissions fall short of what is required in several material respects.

Compare And Contrast The Lewis And Clark Expedition

Although the Court shall address each of these defects at various points in this memorandum opinion, two warrant mentioning at the outset because they are recurring and have hindered the NHTSA's ability to render a meaningful response and complicated this Court's resolution of the instant motion. In each instance, Glass fails to support her response with citations to competent evidence in the record, electing instead to rely upon entirely conclusory and unsupported allegations that her supervisors were somehow guided by an improper motive.

See Def. Glass answers this factual contention as follows: Plaintiff disagrees with the facts stated. This is a material fact in dispute.]

Compare And Contrast The Lewis And Clark Expedition

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