Stevenson v. Bank of America CorporationMOTION for Summary JudgmentN.D. Tex.August 15, 2016IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION ANDRE STEVENSON, Plaintiff, V. BANK OF AMERICA, N.A., Defendant. § § § § § § § § § CIVIL ACTION NO. 3:15-CV-03236-K DEFENDANT BANK OF AMERICA, N.A.’S MOTION FOR SUMMARY JUDGMENT TO THE HONORABLE UNITED STATES DISTRICT COURT: Pursuant to Federal Rule of Civil Procedure 56, Defendant Bank of America, N.A. (“Defendant”) files this Motion for Summary Judgment and, in support thereof, shows the Court as follows: 1. Pursuant to Federal Rule of Civil Procedure 56 and Local Rules 56.1-56.6, Defendant hereby seeks summary judgment on Plaintiff Andre Stevenson’s (“Plaintiff”) claim in this action. 2. Defendant is entitled to summary judgment on Plaintiff’s claim for retaliation because Plaintiff cannot establish a causal connection between a protected activity and Defendant’s failure to hire him. 3. Each of the matters required by Local Rule 56.3(a) are set forth in Defendant’s Brief in Support of its Motion for Summary Judgment, filed contemporaneously with this Motion and incorporated herein by reference as if set forth in full. 4. In support of this Motion, Defendant relies upon the evidence contained in the Appendix in Support of Defendant’s Motion for Summary Judgment, filed contemporaneously with this Motion. Case 3:15-cv-03236-K Document 36 Filed 08/15/16 Page 1 of 2 PageID 157 WHEREFORE, PREMISES CONSIDERED, Defendant Bank of America, N.A. requests that this Court grant summary judgment on Plaintiff’s claim, award Defendant its costs, and grant Defendant such other and further relief to which it may be justly entitled. By: /s/ Jacob A. Lewis Jacob A. Lewis State Bar No. 24087924 MCGUIREWOODS LLP 2000 McKinney Ave., Suite 1400 Dallas, Texas 75201 Telephone: 214.932.6425 Facsimile: 214.273.7493 jlewis@mcguirewoods.com Teri L. Danish Texas Bar No. 05375320 MCGUIREWOODS LLP 600 Travis St. Suite 7500 Houston, Texas 77002 Telephone:713.571.9191 Facsimile: 713.571.9652 tdanish@mcguirewoods.com ATTORNEY FOR DEFENDANT BANK OF AMERICA, N.A. CERTIFICATE OF SERVICE I hereby certify that on August 15, 2016, the foregoing document was duly served in accordance with the provisions of Rule 5 of the Federal Rules of Civil Procedure as follows: Via Electronic Mail steve@thorpehatcher.com Steven B. Thorpe Carla S. Hatcher THORPE, HATCHER & WASHINGTON, PLLC 2214 Main Street Dallas, Texas 75201 /s/ Jacob A. Lewis Jacob A. Lewis Case 3:15-cv-03236-K Document 36 Filed 08/15/16 Page 2 of 2 PageID 158
