Free Other Notice - District Court of Arizona - Arizona

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Mishka L. Marshall (#016641) MARSHALL LAW GROUP, P.C. 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Telephone: 602/274-7873 Facsimile: 602/274-8207 Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

SEAN L. HARGROW, Case No. CIV 2003-0642 PHX DGC Plaintiff, V. FEDERAL EXPRESS CORPORATION, a Delaware corporation doing business in Arizona; JOHN and JANE DOES I-X;
BLACK CORPORATION I-X, WHITE LIMITED LIABILITY COMPANIES I-X,

PLAINTIFF'S PROPOSED VERDICT FORM

Defendants.

The verdict in this case will be determined by your answers to a series of questions set forth below. Make sure that you read the questions and notes carefully because they explain the order in which questions should be answered and which questions may be skipped. Do you find by a preponderance of the evidence: 1. That the Defendant retaliated against Sean Hargrow for having exercised

his rights under the federal Civil Rights Act of 1964, Title VII or 42 U.S.C. § 1981? Yes ____________________ No _____________________

Case 2:03-cv-00642-DGC

Document 137

Filed 11/02/2006

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If your answer to Question 1 is No, you will not answer any additional questions. 2. That, as a result of the retaliation, Sean Hargrow should

be awarded damages to compensate for a net loss of wages and benefits to the date of trial? Yes ____________________ No _____________________

If your answer is Yes, in what amount? $_______________________ (fill in amount) 3. That, due to retaliation, Sean Hargrow should be awarded damages to

compensate him for emotional pain and mental anguish? Yes ____________________ No _____________________

If your answer is Yes, in what amount? $_______________________ (fill in amount) 4. That a higher management official of the Defendant acted with malice or

reckless indifference to Sean Hargrow's rights to be free from retaliation as protected by either the federal Civil Rights Act of 1964, Title VII or 42 U.S.C. § 1981?

Yes ____________________

No _____________________

If your answer is Yes, what amount of punitive damages, if any, should be assessed against Defendant? $_______________________ (fill in amount)

SO SAY WE ALL. Foreperson ______________________

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Date __________________________

Respectfully submitted this 2nd day of November, 2006. MARSHALL LAW GROUP, P.C.

Mishka L. Marshall Mishka L. Marshall 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on November 2, 2006 I transmitted by electronic filing the foregoing Plaintiff's Proposed Verdict Forms to the United States District Court for the District of Arizona using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Mary H. Beard FEDERAL EXPRESS CORPORATION 3620 Hacks Crossing Road, Building B-3rd Floor Memphis, Tennessee 38125 Lori Higuera Alec Hillbo FENNEMORE CRAIG, PC 3003 North Central Avenue, Suite 2600 Phoenix, Arizona 85012-2913 Counsel for Defendant s/Mishka L. Marshall Mishka L. Marshall

Case 2:03-cv-00642-DGC

Document 137 3 - Filed 11/02/2006

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