Free Statement - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Stephen G. Montoya (#011791) MONTOYA JIMENEZ, P.A.
The Great American Tower 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012 (602) 256-6718 (fax) 256-6667

[email protected] Attorney for Plaintiffs

Brian Goodwin JoEllen Benton SHUGHART THOMSON & KILROY, P.C.
One Columbus Plaza 3636 North Central Avenue, Ste. 1200 Phoenix, Arizona 85012 (602) 650-2068 (fax) 264-7033

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Beth D'Aguanno and Frankie Tyree, plaintiffs, vs. American Builders & Contractors Supply Co., Inc., doing business as ABC Supply Company, Inc., defendant. The parties to this dispute hereby submit the following Joint Statement of the Case to be read to the jury in this matter: Ms. Beth Ann D'Aguanno and Ms. Frankie Tyree are former employees at the Mesa branch of ABC Supply Company in Mesa, Arizona. ABC Supply provides building materials to the roofing industry throughout the Valley and the United States. During their respective tenures of employment at ABC Supply, Ms. D'Aguanno and Ms. Tyree claim that they were subjected to sexual harassment by their supervisors and coworkers at ABC Supply. Ms. No. CV 03-1408-PHX-DGC Joint Statement of the Case

Case 2:03-cv-01408-DGC

Document 75

Filed 08/19/2005

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

D'Aguanno and Ms. Tyree also claim that although they complained of the sexual harassment to their supervisors at ABC Supply, the harassment continued until their employment with the Company ultimately ended. ABC Supply denies that either Ms. D'Aguanno or Ms. Tyree was subjected to sexual harassment in the workplace and also denies that it failed to promptly respond to any complaints of harassment made by either Ms. D'Aguanno or Ms. Tyree. Dated the 19th day of August, 2005.

MONTOYA JIMENEZ A Professional Association s/ Stephen G. Montoya Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiffs s/ JoEllen Benton Brian Goodwin JoEllen Benton Shughart Thomson & Kilroy, P.C. One Columbus Plaza 3636 North Central Avenue, Ste. 1200 Phoenix, Arizona 85012

-2-

Case 2:03-cv-01408-DGC

Document 75

Filed 08/19/2005

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

CERTIFICATE OF SERVICE

:

I hereby certify that on August 19, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Brian Goodwin JoEllen Benton Shughart Thomson & Kilroy, P.C. One Columbus Plaza 3636 North Central Avenue, Ste. 1200 Phoenix, Arizona 85012

:

I further certify that on August 19, 2005, the attached document was also sent via United States First Class Mail, postage prepaid to:

The Honorable David G. Campbell United States District Court for the District of Arizona Sandra Day O'Connor United States Courthouse 401 West Washington Street Phoenix, Arizona 85003

s/ Stephen G. Montoya

-3-

Case 2:03-cv-01408-DGC

Document 75

Filed 08/19/2005

Page 3 of 3