In Ambromovage v. United Mine Workers of America, 726 F.2d 972 (3d Cir.1984), the Court set out a tripartite test by which such supplemental (ancillary and pendent) jurisdiction should be judged. First, pursuant to United Mine Workers v. Gibbs, 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed.2d 218 (1966), the court must possess constitutional power to hear the claim. Second, the extension of jurisdiction cannot contravene or undermine federal statutory law. Third, the court must examine whether, in the exercise of its appropriate discretion, the claim is of the type to which supplemental jurisdiction should be extended. Ambromovage, 726 F.2d at 989-91. The Court stated that "in the absence of an explicit congressional directive, the awarding of prejudgment interest under federal law is committed to the trial court's discretion." Id. at 981-82. Pre-judgment interest is to be "given in response to considerations of fairness and denied when its exaction would be inequitable." Id. at 982.