IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Civil Action No. 1:05cv0961 (EGS)
HOGAN & HARTSON, LLP,
Defendant Hogan and Hartson, LLP, by its attorneys, answers the Complaint in this
action as follows:
The Complaint fails to state a claim against Defendant upon which relief may be granted.
Defendant responds to the numbered allegations contained in the Complaint as follows:
Paragraph 1 constitutes a characterization of Plaintiff’s cause of action to which
no response is required. To the extent a response is required, Defendant denies the allegations.
JURISDICTION AND VENUE
Defendant admits that this Court has jurisdiction over this action but denies that
the Court has jurisdiction pursuant to 28 U.S.C. §§ 1337 or 1346.
Defendant admits that venue is proper in the District of Columbia but denies that
it committed any alleged unlawful employment practice with respect to Plaintiff.
Case 1:05-cv-00961-EGS Document 3 Filed 09/29/2005 Page 1 of 7
LANICE v. HOGAN AND HARTSON LLP
- 2 -
Defendant admits, upon information and belief, the first sentence of Paragraph 4.
As to the last sentence of Paragraph 4, Defendant admits that Defendant formerly employed
Defendant admits that it is an international law firm organized under the laws of
the District of Columbia and doing business in the District of Columbia.
FACTS COMMON TO ALL COUNTS
Defendant admits that it employed Plaintiff in its Accounting Department from
December 19, 1994 through July 6, 2004 when Plaintiff resigned in lieu of termination of her
employment. Defendant admits the allegations contained in the second sentence of Paragraph 6.
Defendant admits that Plaintiff received performance evaluations, which speak for themselves.
Defendant admits that, at the time of her departure in June 2004, Plaintiff supervised five
employees. Defendant denies the remaining a