Rowe v. Pacific Quad, Inc. Plaintiffs Version

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5th Edition
ISBN: 9781601563477
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5th Edition
ISBN: 9781601566171
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In this deposition skills file, Alice Rowe has brought an action under Title VII of the 1964 Civil Rights Act and the Nita Fair Employment Act (which is identical to the California Fair Employment & Housing Act) for sexual harassment and wrongful discharge against her employer, Pacific Quad, Inc. She asserts that her supervisor, operations manager Stanley Schmit, continually leered at her, made offensive sexually suggestive comments to her, brushed by her in order to sexually touch her, and, finally, propositioned her during the two weeks she worked for Pacific Quad. She further alleges that the president of Pacific Quad, John Walsh, was informed of the harassment and ratified it.

Rowe claims lost wages, medical expenses (psychotherapy), general damages for emotional distress, and punitive damages.

Witnesses may be deposed on the issue of liability only or liability and damages. There are three witnesses for the plaintiff and three for the defendant. The plaintiff and defendant versions are self-contained and can be used independently of each other to teach deposition skills.

A trial version of Rowe v. Pacific Quad, Inc. is also available. The deposition and trial files are fully integrated, so that students may use the deposition materials to study deposition practice, using the NITA method, and then go on to study trial practice using the trial materials.

A CD with exhibits is included with the file.

Authors / Contributors

Table of Contents

Contents

Introduction

Materials Available to All Sides

Special Instructions for Use as a Deposition File
Pleadings
     Complaint
     Answer

Materials Available Only to the Plaintiff's Attorneys
Statements
      Alice Rowe
      Anna Mills
      Gloria Warner

Documents Available to All Sides
Exhibits
      Office Floor Plan of Pacific Quad, Inc.
      Benjamin Cohen's Letter to Henry Glenn, January 25, YR-0
      NSU Grievance Board Complaint Form
      NSU Grievance Board Decision
      Rowe Resume
      Rowe's Application for Employment
      Pacific Quad List of Permanent Employees
      John Walsh's Letter to Alice Rowe
      Records of Nita Department of Fair Employment
      E-mails
      Resumes
      John Walsh's Letter to Annie Cunningham
      Statement of Susan Robinson
      Right to Sue Letter
      Anna Mill's Letter to Saul Jacob

Legal Memorandum and Court of Appeals Opinion