Free Proposed Verdict Form - District Court of Connecticut - Connecticut

Case 3:00-cv-01124-WIG Document 173 Filed 05/15/2007 Page 1 of 4
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UNITED STATES DISTRICT COURT I I if A n I I
DISTRICT OF CONNECTICUT
DENISE EVARTS :
Plaintiff
: Civil No. 3:00CVl 124 (WIG)
V. :
THE SOUTHERN NEW :
ENGLAND TELEPHONE COMPANY, : May 10, 2007
Defendant
PLAINTIFF’S PROPOSED VERDICT FORM
A. LIABILITY P
l. Do you find, by a preponderance of the evidence, that SNET, through its management,
subjected the plaintiff to a hostile and offensive working environment on the basis of gender in
violation of 42 U.S.C. §2000e gt. gl.?
Answer:
Yes _,_ No ___
2. Employing the reasonable person standard explained in the COl.1I'lZ’S instructions, do you
find that the plaintiff reasonably felt compelled to leave her work environment at SNET for the sake
of her own physical and emotional well-being and thus was constructively discharged from her
employment by SNET?

Case 3:00-cv-01124-WIG Document 173 Filed 05/15/2007 Page 2 of 4
Answer: l
‘ Yes ; No__
B. DAMAGES - BACK PAY AND COMPENSATORY
1. What amount of back pay and other compensation do you find that plaintiff lost as a result
of her constructive discharge after taking into account any income Evarts earned from other
employment during the three year period following her constructive discharge?
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2. What amount, if any, do you award the plaintiff as non—economic compensatory damages
for such injuries as emotional distress, upset, anguish, embarrassment, inconvenience, humiliation
or reputational injury?
$ .
C. PUNITIVE DAMAGES
1. Do you find that defendant’s conduct was not merely negligent but willful and malicious
g such that such conduct was committed in reckless disregard of the plaintiffs federal rights?
Answer:
Yes _ N0_ `
2. If your answer to C.l. above is “Yes", what amount of punitive damages do you find is
necessary for both punitive ptuposes and to deter SNET and other employers from engaging in like
conduct in the future?
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Case 3:00-cv-01124-WIG Document 173 Filed 05/15/2007 Page 3 cf 4
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THE PLAINTIF F
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BY: `
KAREN LEE TORRE
Federal Bax N0. ct01707
Law Offices 0fKa1·en Lee Terre
51 Elm Street, Suite 307
New Haven, CT 06510
(203) 865-5541
Her Attorney
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Case 3:00-cv-01124-WIG Document 173 Filed 05/15/2007 Page 4 of 4
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed, First Class, postage paid, on May
10, 2007, to:
Lori B. Alexander, Esq.
Theresa M. Waugh, Esq.
Deborah DeHart Cannavino, Esq.
Littier Mendelson, P.C.
110 Washington Avenue
North Haven, CT 06473
David Vegilante, Esq.
Southern New England Telephone Co
310 Orange St., Sth Fl.
New Haven, CT 06510
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Kargri Lee Torre U
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