Case 1 :04-cv-01450-JJF Document 51 Filed 11/16/2006 Page 1 of 3
I IN T`HE UNITED STATES DISTRICT COURT
FOR T'HE DISTRICT OF DELAWARE
CAS SANDRA JOHNSON :
Plaintiff] CIVIL ACTION
: NO. 04-1450 (JJF)
v. :
_ WAL-MART STORES, INC., ~
a Delaware corporation :
Defendant
DEFENDANTS PROPOSED VERDICT SHEET
l. Did plaintjff prove by a preponderance ofthe evidence that SAM’S
violated the Equal Pay Act, 29 U.S.C. § 206‘?
_ _ Yes 1 No
Ifyou have answered “Yes" to the above question, please proceed to question 2.
Ifyou have answered “No†to the above question, please proceed to question 3.
2. Did plaintiff prove by a preponderance of theevidence that SAM’s
violation ofthe Equal Pay Act was willful?
_ Yes _1 No
Please proceed to question 3.
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Case 1 :04-cv-01450-JJF Document 51 Filed 11/16/2006 Page 2 of 3
3. Did plaj.n1:i.ff prove by a preponderance of the evidence that SAM’S
discriminated against her on the basis of sex in violation of 42 U.S.C. § 2000e‘?
__ Yes ______ No
Ifyou have answered "`Yes" to either question l or 3, please proceed to question
4. Ifyou have answered “No†to questions 1 and 3, please stop here and sign the
next page.
4. Please state, in monetary terms, the total amount of back pay and/or
compensatory damages that you find Plaintiff Cassandra Johnson suffered as a result of SAM’S
actions?
Back Pay $
Compensatory Damages: $_
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Case 1:04-cv-01450-JJF Document 51 Filed 11/16/2006 Page 3 of 3
When you have completed this document, please sign and date the Verdict Sheet.
Dated:
Foreperson
Respectfully Submitted,
Dated: November 16, 2006 /s/ William M. Kelleher
William M. Kelleher (#3 961)
Ballard Spahr Andrews & Ingersoll, LLP
919 Market Street, 17th Floor
Wilmington, DE 19801
(3 02) 252-4460
Attorneys for Defendant
Wal—Mart Stores, Inc.
OF COUNSEL:
David S. Fryrnau
Farrah I. Gold
Ballard Spahr Andrews & Ingersoll, LLP
1735 Market Street, 51* Floor
Philadelphia, PA 19103-7599
(Z215)665-8500
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