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Case 1:10-cv-02280-SCJ

Document 119

Filed 01/31/13

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF'GEORGIA

ATLANTA DIVISION

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LISA KARAS,

Plaintiff'

CIVIL ACTION NO.

1:10-CV-2280-SCJ

NEW NGC, INC.,

Defendant.

SPECIAL INTERROGATORIES TO THE JURY ANd VERDICT FORM

Do you find from a preponderance of the evidence:

1. That the Plaintiff was discharged from employment by the Defendant?

Answer Yes or No

2. That the PlaintifPs sex orgender was a substantial ormotivating factor that prompted

the Defendant to take that action?

Answer Yes or No

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[Ng!g: If you answered No to either Question No. 1 or Question No.2 you need not rnswer the remaining questions.]

3. That the Plaintiff would have been discharged from employment for submitting a fraudulent expense report and not being truthful about it when confronted by her

manager regardless of the Plaintiff s sex or gender?

Answer Yes or No

Case 1:10-cv-02280-SCJ

Document 119

Filed 01/31/13

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That the Plaintiff should be awarded damages to compensate for a net loss ofwages

and benefits?

Answer Yes or No

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5. Ifyou found that the Plaintiffshould be awarded damages for a net loss ofwages and

benefits, has it been proved that even if the Plaintiff had not been terminated on October 7,2008, the Defendant would have terminated the Plaintiff s employment by January 18, 201I, because it leamed that Plaintiff, at the time she was hired,

submitted an employment application and resume that knowingly misrepresented

Plaintiffas having graduated from high school with a diploma and having graduated

from Cwinnett

Technical College?

Answer Yes or No

, /1.1

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Ifyour answer is No, then enter the amount ofnet loss ofwages and benefits

to the date oftrial.

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Ifyour answer is Yes, then enter the amount ofnet loss ofwages and benefits - limiting your award ofbackpay to the date the Defendant would have made

the decision to discharge Plaintiffas a result ofafter-acquired evidence.

Amount, agW6i

6. That the Plaintiffshould be awarded damages to compensate for emotional pain and

7 (a)

mental ansuish?

Answer Yes or No

Ifyour answer is Yes,

in what amount?

$ /D oo 0,"

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That a higher management official of the Defendant acted with malice or reckless

indifference to the Plaintiffs federally protected rights?

Answer Yes or No

NO

(b) Ifyour answer to 7(a) is Yes, do you further find that the Defendant itself had not

acted in a good faith attempt to comply with the law by adopting policies and procedures designed to prohibit such discrimination in the workplace?

Answer Yes or No

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Case 1:10-cv-02280-SCJ

Document 119

Filed 01/31/13

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SAY WE ALL, signed and dated at the United States Courthouse, Atlanta, Georgi4 this

dav ofJanuarv.20l3.

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Foreperson's Signatue

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Foreperson's Printed Narne

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