Free Status Report - District Court of Delaware - Delaware

Case 1 :05-cv—00704-GIVIS Document 6 Filed 12/12/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JANE CZARNECKI )
Plaintiff, g
v. j C.A. N0.: 05-704 (GMS)
j .IURY TRIAL DEMANDED
SMITH VOLKSWAGEN, LTD. )
a Delaware Corporation )
Defendant. j
JOINT STATUS REPORT
The parties, through their respective counsel, hereby provide information ordered by the
Court in contemplation of a Scheduling Conference inthe above-captioned matter on December 19,
2005.
l. Jurisdiction and Service. The parties agree that this Court has subject matter
jurisdiction and that all parties are subject to the Court’ s jurisdiction. No parties remain to be served.
2. Substance of the Action. This is a Sexual Harassment, Sex Discrimination and
Retaliation case under Title VII. The substance of the action is outlined in Plaintiffs Complaint.
3. Identification of Issues. The parties refer the Court to their respective positions
contained in the Complaint and Answer. The case involves factual issues as to whether or not sexual
harassment occurred, what Defendant’ s response, if any, was to the alleged harassment, and the facts
regarding Plaintiff s termination. At this time, the parties are not aware of any specific legal issues
other than the application of the facts to controlling law.
4. Narrowing of Issues. The parties do not anticipate dispositive motions.
5. Relief. Plaintiff seeks compensatory damages, including pain and suffering type

Case 1 :05-cv—00704-GIVIS Document 6 Filed 12/12/2005 Page 2 of 3
damages, economic loss (including back pay and front pay), punitive damages and Attorney’s fees.
Plaintiff s Counsel is awaiting information from Plaintiff regarding her 2005 earnings in order to
compute the economic loss component of her damages and, therefore, is not currently in a position
to state the dollar amount of relief sought. Plaintiff intends to have more information for the Court
by the time of the Scheduling Conference.
6. Amendment of Pleadings. None are contemplated at this time.
7. Joinder of Parties. None anticipated.
8. Discovery. The parties anticipate that it will take approximately 12 months to
complete discovery. The parties anticipate written discovery followed by depositions. There are a
large number of witnesses to be deposed, including principals and eyewitnesses. Unforttmately,
Cotmsel has not identified a less costly alternative for performing discovery other than through
traditional deposition methods.
9. Estimated Trial Length. Due to the large number of witnesses, the parties anticipate
a five day trial. The specific length of trial will be easier to ascertain after discovery is completed.
10. Jury Trial. Yes.
1 1 . Settlement. Unsuccessful Mediation was held at the Delaware Department of Labor.
At that time, Defendant was represented by different Counsel. However, both parties are agreeable
to attempting mediation again. Counsel intend to engage in informal settlement discussions as soon
as Plaintiff makes a demand for settlement.
l2. Other Matters. None.
13. Counsel for the parties have conferred about each of the above matters.

Case 1 :05-cv—00704-GIVIS Document 6 Filed 12/12/2005 Page 3 of 3
KNEPPER & STRATTON TYBOUT, REDFEARN & PELL
/s/ Barbara H. Stratton /s/ David G. Culley
BarIDNo. 2785 Bar ID No. 2141
1228 N. King Street 300 Delaware Avenue
P.O. Box 1795 Suite 1100
Wilmington, DE 19899 Wilmington, DE 19801
(302) 652-7717 (302) 658-6901
Attorney for Plaintiff Attorney for Defendant
Date: December 12, 2005 Date: December 12, 2005