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I agree, and she has also failed to adequately
show that it would “fair and just” to allow the amendment at such a
late stage. I’ve already begun putting pen-to-paper on this. While it
is ultimately in the discretion of the judge whether to allow an amendment and they
are usually liberal when it comes to amendments, we do have solid prejudice and
timing arguments that cannot be ignored and have been ruled in previous cases to
be enough to deny a plaintiff’s motion for leave to amend… John E. Murray, Esq. Associate Attorney Rachlis Durham Duff Adler
& Peel, LLC Office: (312) 733-3950 Direct: (312) 275-0338 Fax: (312) 733-3952 Email: jmurray@rddlaw.net Firm website: www.rddlaw.net RACHLIS This transmission may be: (1) subject to
the Attorney-Client Privilege, (2) an attorney work product, or (3) strictly
confidential. If you are not the intended recipient of this message, you may
not disclose, print, copy or disseminate this information. If you have received
this in error, please reply and notify the sender (only) and delete the
message. Unauthorized interception of this e-mail is a violation of federal
criminal law. From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] It appears that she
failed to understand the judge’s order regarding what she can amend which
doesn’t surprise me. Voir dire thought: No one would
disagree that using the N word justifies firing someone. Shouldn’t
every racial, gender, and ethnic epithet receive the same treatment? From: Kevin Duff
[mailto:kduff@rddlaw.net] Agreed From: Wolford Lisa
[mailto:lisa@csss.net] Btw, I am of German, Irish, Scottish and
a smidgen of American Indian descent so neither the Pollack or Dago reference
were personal to me. My issue with such statements at a company party is
they are derogatory regarding particular ethnicities. This cannot be
allowed by an employer. To not take such references seriously would
basically endorse them. As a matter of business practice I disciplined a
corporate management employee in Mr. Cynowa's technical skills were never in question, his
professional demeanor (the lack thereof) was the issue. It is unlikely that Mr. Slater made taunting statements, it
is completely counter to his personality style. Btw, in the email from Randy Padal, the Larry mentioned is
not Mr. Carver it is the PM prior to Mr. Slater. His name is Larry
McKeehan and he was let go for cause. Since it is unverifiable that Slater repeated any statements
to anyone it is probably more likely that Mr. Cynowa made statements to to
others about his belief that slater believed he had a gun thereby damaging his
own reputation. Lisa N. Wolford CSSS.NET 402-393-8059w 402-393-1825f SDVOB, 8(a)/SDB & WOB - TS clearances From: Kevin
Duff [mailto:kduff@rddlaw.net] Lisa and Bill, Attached is Cynowa’s motion for
leave to amend his complaint along with the proposed second amended
complaint. Our response to the motion is due May 5. Kevin From: THERESA JOHNSON
[mailto:theresavjohnson@prodigy.net]
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