Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cv-00973-DJS

Document 36-2

Filed 06/15/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ________________________________ LISA TILUM : CIVIL ACTION NO: 3:03 CV973 (DJS) Plaintiff : : VS. : : STATE OF CONNECTICUT, : DEPARTMENT OF TRANSPORTATION: Defendant : ________________________________: JUNE 10, 2004 PLAINTIFF=S PROPOSED JURY INTERROGATORIES AND VERDICT FORM We the jury find as to: COUNTS I AND II: Title VII and Connecticut Fair Employment Practices Act

1. Has the plaintiff proven her claims of sex discrimination or retaliation as I have defined those claims? Yes No

If your answer to No. 1 is ANo@, go on to COUNT III.. If your answer to No. 1 is AYes@, go on to No. 2. 2. What sum do you find will fairly and reasonably compensate the plaintiff? $ 3. Has the Defendant acted intentionally in this regard? Yes No

Case 3:03-cv-00973-DJS

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Filed 06/15/2004

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COUNT III:

Equal Pay Act

1. Has plaintiff proven her Equal Pay Act claim as I have defined that claim? Yes No

If your answer to No. 1 is ANo@, your deliberations are concluded. If your answer to No. 1 is AYes@, go on to No. 2. Willfulness 2. Do you find that the defendant knew or showed reckless disregard for wether its conduct was prohibited by law? Yes No

If your answer to No. 2 is ANo@, answer only No. 3 below. If your answer to No. 2 is AYes@, answer only No. 4, and not No. 3 below.

Damages 3. What sum do you find will fairly and reasonably compensate plaintiff? For the period from May 21, 2002, or from the date on which you find the violation began (whichever is later) through the present? $ 4. What sum do you find will fairly and reasonably compensate plaintiff? For the period from May 21, 2001, or from the date on which you find the violation began (whichever is

Case 3:03-cv-00973-DJS

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Filed 06/15/2004

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later) through the present? $ III. TOTAL RECOVERY

Keeping in mind that Plaintiff cannot recover twice for the same injury, what is your total award for the Plaintiff? $ Dated at Hartford, Connecticut, this day of , 2004. Foreperson

Case 3:03-cv-00973-DJS

Document 36-2

Filed 06/15/2004

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PLAINTIFF By: Kathleen Eldergill Federal Bar No.ct00024 Beck & Eldergill, P.C. 447 Center Street Manchester, CT 06040 Tel: (860) 646-5606

CERTIFICATION I hereby certify that a copy of the foregoing was mail to the following this 11th day of June, 2004: Margaret Q. Chapple Assistant Attorney General Attorney General=s Office 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120

Kathleen Eldergill
Tilum\JuryInter.pld