Free Other Notice - 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

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. Pursuant this Courts Order of June 22, 2005, Plaintiffs submit Proposed Form of Verdict. Dated the 19th day of August, 2005. the following No. CV 03-1408-PHX-DGC Plaintiffs' Forms of Verdict

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

Case 2:03-cv-01408-DGC

Document 71

Filed 08/19/2005

Page 1 of 4

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

FORM OF VERDICT FOR PLAINTIFF BETH D'AGUANNO The jury must unanimously agree on the answers to the following questions: 1. Has Ms. D'Aguanno proven by a preponderance of evidence that she was subjected to a sexually hostile work environment­as defined by the Court's instructions­while employed by ABC Supply Company, Inc.? YES_______ 2. NO_______ If your answer to Question 1 is "YES," then proceed to Questions 2 and 3. State the amount of compensatory damages­if any­that Ms. D'Aguanno should be awarded against ABC Supply Company, Inc. on her sexually hostile work environment claim. AMOUNT 3. $___________ Now please answer Question 3. State the amount of punitive damages­if any­that Ms. D'Aguanno should be awarded against ABC Supply Company, Inc. on her sexually hostile work environment claim. AMOUNT $___________

-2-

Case 2:03-cv-01408-DGC

Document 71

Filed 08/19/2005

Page 2 of 4

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

FORM OF VERDICT FOR PLAINTIFF FRANKIE TYREE The jury must unanimously agree on the answers to the following questions: 1. Has Ms. Tyree proven by a preponderance of evidence that she was subjected to a sexually hostile work environment­as defined by the Court's instructions­while employed by ABC Supply Company, Inc.? YES_______ 2. NO_______ If your answer to Question 1 is "YES," then proceed to Questions 2 and 3. State the amount of compensatory damages­if any­that Ms. Tyree should be awarded against ABC Supply Company, Inc. on her sexually hostile work environment claim. AMOUNT 3. $___________ Now please answer Question 3. State the amount of punitive damages­if any­that Ms. Tyree should be awarded against ABC Supply Company, Inc. on her sexually hostile work environment claim. AMOUNT $___________

-3-

Case 2:03-cv-01408-DGC

Document 71

Filed 08/19/2005

Page 3 of 4

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

-4-

Case 2:03-cv-01408-DGC

Document 71

Filed 08/19/2005

Page 4 of 4