Free Statement - District Court of Arizona - Arizona

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David C. Larkin #006644 DAVID C. LARKIN, P.C. 4645 South Lakeshore Drive, Suite 6 Tempe, Arizona 85282 Telephone (480) 491-2900 Fax (480) 755-4825 William P. Allen #011161 ALLEN LAW FIRM, LLC 1650 North First Avenue Phoenix, Arizona 85003 Telephone (602) 495-6502 Fax (602) 277-9839 Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Connie B. Pappas, Plaintiff, vs. J.S.B. Holdings, Inc., d.b.a. R&D Specialty/Manco, Defendant. Since the filing of the original Joint Pretrial Statement, plaintiff has decided not to pursue her Title VII retaliation claim at trial and to forego requesting an instruction on that claim. She will try only her Title VII hostile work environment sex discrimination and constructive discharge claim. Accordingly, if the Court will read a statement of the case to the jury at trial, plaintiff proposes the following neutral statement of the case: // // // // // // // No. CV-03-1449-PHX-PGR PLAINTIFF'S PROPOSED STATEMENT OF THE CASE

Case 2:03-cv-01449-PGR

Document 86

Filed 06/12/2006

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STATEMENT OF THE CASE In this case, the plaintiff, Connie Pappas, alleges that the defendant, JSB Holdings, Inc., her former employer, unlawfully discriminated against her by subjecting her to a hostile work environment because of her sex. Ms. Pappas further alleges that this harassment, and her employer's failure to do anything about it, caused her working conditions to be so intolerable that she was forced to quit. She alleges that she suffered lost wages and emotional distress as a result of the discrimination. JSB Holdings denies that it discriminated against her, denies that co-workers harassed her because of her sex, and further denies that her working conditions were so intolerable that she was forced to quit and that she is entitled to damages. Respectfully submitted this 12th day of June, 2006. DAVID C. LARKIN, P.C. By: /s David C. Larkin David C. Larkin and ALLEN LAW FIRM, LLC By: /s William P. Allen William P. Allen Attorneys for Plaintiff

Electronic notice and service of documents provided to: Sharon S. Moyer No. 013341 Mark D. Dillon No. 014393 SACKS TIERNEY P.A. 4250 N. Drinkwater Blvd., 4th Floor Scottsdale, AZ 85251-3693 Attorneys for Defendants /s David C. Larkin

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Case 2:03-cv-01449-PGR

Document 86

Filed 06/12/2006

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