Free Statement - District Court of Arizona - Arizona

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MARY JO O'NEILL, AZ Bar No. 005924 SALLY C. SHANLEY, AZ Bar No. 012251 KATHERINE J. KRUSE, AZ Bar No. 019167 MICHELLE G. MARSHALL, AZ Bar No. 017358 VALERIE L. MEYER, CA Bar No. 228586 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Phoenix District Office 3300 North Central Avenue, Suite 690 Phoenix, Arizona 85012 Telephone: (602) 640-5029 e-mail: [email protected] [email protected] Attorneys for Plaintiff J. MARK OGDEN, AZ Bar No. 017018 J. GREG COULTER, AZ Bar No. 016890 KRISTIN R. CULBERTSON, AZ Bar No. 20801 LITTLER MENDELSON A Professional Corporation Camelback Esplanade 2425 E. Camelback Rd., Suite 900 Phoenix, Arizona 85016-4242 Telephone: 602.474.3600 e-mail: [email protected] [email protected] [email protected] Attorneys for Defendants

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Equal Employment Opportunity Commission, Plaintiff, vs. Connecticut General Life Insurance Company, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) CIV 04-0627-PHX-JAT

JOINT PROPOSED STATEMENT OF THE CASE

Plaintiff, the Equal Employment Opportunity Commission, and Defendant, Connecticut General Life Insurance Company, in accordance with this Court's Order setting the final pretrial conference, attempted but were unable to reach agreement on a joint statement, and set forth each of their proposed statements of the case below. \\ \\

Case 2:04-cv-00627-JAT

Document 118

Filed 06/26/2006

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I.

Plaintiff's Proposed Statement of the Case This is a case brought under Title VII of the Civil Rights Act of 1964 by the

United States Equal Employment Opportunity Commission against Connecticut General Life Insurance Company on behalf of Carmen Santa Cruz. In November 2001, Ms. Santa Cruz applied and interviewed for a position as a customer service associate with Defendant Connecticut General Life Insurance Company, doing business as CIGNA. The EEOC claims that the Defendant unlawfully discriminated against Carmen Santa Cruz based on her sex when it failed to hire Ms. Santa Cruz upon learning she was pregnant, in violation of Title VII. The EEOC also alleges that Ms. Santa Cruz is entitled to lost wages and compensation for emotional harm, as well as an award of punitive damages. Defendant claims that it did not fail to hire Ms. Santa Cruz because of her pregnancy. Thus, Defendant also alleges that it is not liable for any lost wages or compensatory or punitive damages. II. Defendant's Proposed Statement of the Case This case is brought under Title VII of the Civil Rights Act of 1964 by the United States Equal Employment Opportunity Commission against Connecticut General Life Insurance Company ("CGLIC") on behalf of Carmen Santa Cruz. In November 2001, Ms. Santa Cruz applied for, interviewed for, and was offered a position as a customer service associate with Defendant CGLIC. Ms. Santa Cruz contends that once CGLIC learned she was pregnant the offer of employment was withdrawn because of her pregnancy, in violation of Title VII of the Civil Rights Act of 1964. CGLIC contends that it never withdrew the offer and, instead, Ms. Santa Cruz declined the offer of employment. Plaintiff seeks damages on behalf of Ms. Santa Cruz. RESPECTFULLY SUBMITTED this 26th day of June, 2006. // // //
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Case 2:04-cv-00627-JAT

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s/Katherine J. Kruse Mary Jo O'Neill Sally C. Shanley Katherine J. Kruse Michelle G. Marshall Valerie L. Meyer EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Attorneys for Plaintiff

s/ Kristin R. Culbertson (approved via email 6-26-06 ) J. Mark Ogden, Esq. J. Greg Coulter, Esq. Kristin R. Culbertson LITTLER MENDELSON PC Suite 900 2425 E. Camelback Rd. Phoenix, AZ 85016-4242 Attorneys for Defendants

Case 2:04-cv-00627-JAT

Document 118

Filed 06/26/2006

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