Marrin v. Capital Health et al

MOTION for Summary Judgment

D.N.J.October 10, 2016

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY JANICE MARRIN, Plaintiff, v. CAPITAL HEALTH SYSTEMS, INC., JOAN DUVALL, and CAROLANN BASS, Defendants. CIVIL ACTION NO. 14-cv-02558 Hon. Judge Freda L. Wolfson Magistrate Judge Lois H. Goodman NOTICE OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT Returnable: November 2, 2016 ORAL ARGUMENT REQUESTED TO: Michael S. Harwin Law Office of Michael S. Harwin 28-27 Fair Lawn Avenue Fair Lawn, New Jersey 07410 Attorney for Plaintiff PLEASE TAKE NOTICE that, on November 2, 2016, at 9:00 a.m., or as soon thereafter as counsel may be heard, the undersigned attorneys for Defendants Capital Health Systems, Inc., Joan DuVall, and Carolann Bass (collectively, “Defendants”) shall move before the Honorable Judge Freda L. Wolfson, at Courtroom 5E, Clarkson S. Fisher Building & U.S. Courthouse, 402 East State Street, Trenton, NJ 80608, for an order granting Defendants’ Motion for Summary Judgment pursuant to Federal Rule of Civil Procedure 56. Case 3:14-cv-02558-FLW-LHG Document 68 Filed 10/10/16 Page 1 of 2 PageID: 1106 3 PLEASE TAKE FURTHER NOTICE that, in support of Defendants’ Motion for Summary Judgment, Defendants rely on the accompanying Brief in Support. PLEASE TAKE FURTHER NOTICE that a proposed form of order is submitted herewith. PLEASE TAKE FURTHER NOTICE that Defendants hereby request oral argument. Dated: October 10, 2016 Respectfully Submitted, GREENBERG TRAURIG LLP s/ Kelly Dobbs Bunting Kelly Dobbs Bunting NJ 014042001, PA 88492 Christiana L. Signs NJ 099012014, PA 317851 2001 Market Street Philadelphia, PA 19103 Phone: (215) 988-7868 Fax: (215) 717-5246 buntingk@gtlaw.com signsc@gtlaw.com Attorneys for Defendants Case 3:14-cv-02558-FLW-LHG Document 68 Filed 10/10/16 Page 2 of 2 PageID: 1107 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY JANICE MARRIN, Plaintiff, v. CAPITAL HEALTH SYSTEMS, INC., JOAN DUVALL, and CAROLANN BASS, Defendants. CIVIL ACTION NO. 14-cv-02558 [PROPOSED] ORDER THIS MATTER having been open to the Court by Defendants Capital Health Systems, Inc., Joan DuVall, and Carolann Bass, for an order pursuant to Federal Rule of Civil Procedure 56 entering summary judgment on Plaintiff Janice Marrin’s claims in Defendants’ favor, and the Court having reviewed the papers submitted by Defendants in support of their Motion, and the papers submitted by Plaintiff in opposition, and having heard oral argument, for good cause shown, IT IS on this ___ day of ____________, 2016 ORDERED that Defendants’ Motion for Summary Judgment is GRANTED. The Clerk is hereby directed to enter judgment in Defendants’ favor. Hon. Freda L. Wolfson, U.S.D.J. Case 3:14-cv-02558-FLW-LHG Document 68-1 Filed 10/10/16 Page 1 of 1 PageID: 1108 CERTIFICATE OF SERVICE I, Kelly Dobbs Bunting, hereby certify that on October 10, 2016, I caused a true and correct copy of the foregoing Notice of Defendants’ Motion for Summary Judgment to be served by way of the Court’s Electronic Filing System (ECF) upon the following counsel of record: Michael S. Harwin, Esq. Law Office of Michael S. Harwin 38-27 Fair Lawn Avenue Fair Lawn, New Jersey 07410 Attorneys for Plaintiff s/ Kelly Dobbs Bunting Kelly Dobbs Bunting NJ 014042001, PA 88492 Case 3:14-cv-02558-FLW-LHG Document 68-2 Filed 10/10/16 Page 1 of 1 PageID: 1109