Free Statement - District Court of Arizona - Arizona

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Mary H. Beard Admitted Pro Hac Vice FEDERAL EXPRESS CORPORATION 3620 Hacks Cross Road, Building B-3rd Floor Memphis, TN 38125 Telephone: (901) 434-8061 Facsimile: (901) 434-9279 Email: [email protected] FENNEMORE CRAIG, P.C. Lori A. Higuera (No. 017273) Alec R. Hillbo (No. 020185) 3003 North Central Avenue Suite 2600 Phoenix, AZ 85012-2913 Telephone: (602) 916-5000 Email: [email protected] Email: [email protected] Attorneys for Defendant Federal Express Corporation UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA SEAN L. HARGROW, Plaintiff, v. FEDERAL EXPRESS CORPORATION, a Delaware corporation; JOHN and JANE DOES IX; BLACK CORPORATION I-X; WHITE LIMITED LIABILITY COMPANIES I-X, Defendants. DEFENDANT'S PROPOSED STATEMENT OF THE CASE No. 03-0642 PHX DGC

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P H O E N IX

Defendant Federal Express Corporation hereby submits the following proposed Statement of the Case to be read to the jury.

NNEMORE CRAIG, P.C.

Case 2:03-cv-00642-DGC

Document 128

Filed 11/02/2006

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This is a case action alleging retaliation. Plaintiff worked for Federal Express Corporation as a part-time courier at the SCF station, located in Scottsdale, Arizona. FedEx discharged him based on its Medical Leave of Absence Policy. Plaintiff's

immediate manager at the time of his discharge was Cheryl Montgomery Wilson. Plaintiff claims that his discharge was actually motivated by retaliation against him for complaining about discrimination in the workplace. FedEx Express denies that Plaintiff's complaint played any role in the decision to discharge him, rather FedEx

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Express contends that a legitimate, nondiscriminatory reason led to his discharge. Plaintiff believes that the reason provided by FedEx is false. Dated this 2nd day of November, 2006. Respectfully submitted,

By: /s/Mary H. Beard Mary H. Beard FEDERAL EXPRESS CORPORATION and

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Lori A. Higuera Alec R. Hillbo FENNEMORE CRAIG, P.C. Attorneys for Defendant

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602840

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P H O E N IX

NNEMORE CRAIG, P.C.

Case 2:03-cv-00642-DGC

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Filed 11/02/2006

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