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automatic reinstatement in event that pla agrees to remittitur; granting motion for judgment as a matter of law [63-1] solely to entent that jury's award of 328,597.93 in backpay is VACATED; in all other respects, motion for judgment as a matter of law is DENIED; dft's alternative motion for a remittitur is GRANTED; jgmt previously entered in case is hereby REDUCED to $360,000.00 conditioned on pla's filing her assent to remittitur w/in 15 days of this order; denying motion for new trial [63-2] on condition that pla assents to remittitur. Should pla fail to assent to remittitur w/in time fixed, court will reconsider motion sua sponte and GRANT it on issue of damages only; filed ( by Chief Judge U W. Clemon ) cm (KWC) (Entered: 09/24/2003) 10/14/2003 87 NOTICE of appeal by defendant Goodyear Tire & Rub from District Court decision [80-1] ; notice of appeal, order appealed from and court copy of docket entries w/transmittal letter mailed cm (BST) (Entered: 7
10/15/2003) 10/24/2003 NOTIFICATION by Circuit Court of Appellate docket number #03-15264-G (KWC) (Entered: 10/24/2003) 11/04/2005 96 USCA JUDGMENT as to 87 Notice of Appeal; It is hereby ORDERED that the attached Opinion is entered as Judgment, the USDC judgement is REVERSED and INSTRUCTED to Dismiss plaintiff Ledbetter's complaint with prejudice, Issued As Mandate 11/03/2005 (SRJ, ) (Entered: 11/07/2005) 11/21/2005 97 ORDER OF DISMISSAL with prejudice w/costs hereby taxed against plaintiff consistent with U.S. Court of Appeals-11th Circuit's Mandate 11/2/2005. Signed by Judge U W Clemon on November 21, 2005. (SRJ, ) (Entered: 11/21/2005) 8
Page 1 and 2: No. 05-1074 IN THE Supreme Court of
Page 3 and 4: Defendant’s Exhibit 65 ..........
Page 5 and 6: filed (Vols I & II) [see separate f
Page 7 and 8: cause - jury selected and sworn - o
Page 9: as a matter of law w/attachments fi
Page 13 and 14: 02/26/2004 E-Brief Tendered: Appell
Page 15 and 16: 07/03/2006 Certiorari Granted: SC#
Page 17 and 18: 2. The plaintiff timely filed her c
Page 19 and 20: 15. The defendant had a practice of
Page 21 and 22: VI. Count III - Age Discrimination
Page 23 and 24: 41. The defendant created an enviro
Page 25 and 26: IN THE UNITED STATES DISTRICT COURT
Page 27 and 28: SIXTH DEFENSE To the extent that Pl
Page 29 and 30: disclosure of incriminating documen
Page 31 and 32: citizen of the United States and th
Page 33 and 34: 18) Goodyear admits that plaintiff
Page 35 and 36: 35) Except to the extent expressly
Page 37 and 38: Q. WHERE DO YOU GO TO COLLEGE? A. J
Page 39 and 40: A. WITH THE MECHANICAL, I FINISHED
Page 41 and 42: WORK WITH YOU, UP UNTIL THE END OF
Page 43 and 44: A. OKAY. Q. DID MR. MAUDSLEY - WHAT
Page 45 and 46: CAREERS [*38] AT GOODYEAR AND THEY
Page 47 and 48: ABOUT EIGHT DIFFERENT THINGS THAT H
Page 49 and 50: THE COURT: RESPONSE? MR. GOLDFARB:
Page 51 and 52: * * * * * [*74] Q. WHEN YOU WENT OV
Page 53 and 54: Cross-Examination of Lilly Ledbette
Page 55 and 56: [*208] Q. YOU WERE SUPERVISED BY ME
Page 57 and 58: IT STUNK. I REALLY DIDN’T AGREE W
Page 59 and 60: WAY BELOW THE LEVEL THAT I [*211] W
Page 61 and 62:
Q. AND YOU’RE AT 2728 A MONTH; RI
Page 63 and 64:
BY MR. GOLDFARB: Q. WHAT WAS YOUR U
Page 65 and 66:
Q. DID YOU HAVE ANY - SO YOU HAD TO
Page 67 and 68:
Q. AT THAT PERIOD OF TIME, IT WAS C
Page 69 and 70:
WOULD GIVE ME RAISES TO GET ME UP T
Page 71 and 72:
A. NO. I STAYED DOWN THERE, WHICH W
Page 73 and 74:
ENTER INTO THE MERIT PLAN FOR THAT
Page 75 and 76:
Q. BUT YOU DESTROYED THOSE DOCUMENT
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A. AT THE TIME I EVALUATED MRS. LED
Page 79 and 80:
A. I HAVEN’T THROWN AWAY ANYTHING
Page 81 and 82:
Q. AND HE IS THE AUDITOR WHO DID TH
Page 83 and 84:
HAPPENED WITH THE TIRES - YOU KEEP
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A. I GUESS - WHAT ARE YOU ASKING ME
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EVER WORKED UNDER YOU, OTHER THAN M
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A. I DON’T REMEMBER WHEN THAT WAS
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AND “TOTAL EXPENDITURES.” WHAT
Page 93 and 94:
Cross-Examination of Michael Tucker
Page 95 and 96:
Q. WELL, WHAT DID YOU TELL HER? IF
Page 97 and 98:
A. ON THIS DOCUMENT, NO, SIR. Q. IN
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Q. BUT YOU COULDN’T TELL HER THAT
Page 101 and 102:
Q. DO YOU KNOW WHERE IT IS? A. NO,
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DISCRIMINATE ON THE BASIS OF SEX IN
Page 105 and 106:
Delivery of Jury Verdict [*476] THE
Page 107 and 108:
III. IV. I could not stay in proces
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STATE OF ALABAMA ) ) COUNTY OF CALH
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work load, Mr. Yarbrough told me th
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THE GOODYEAR TIRE & RUBBER COMPANY
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* * * * * TO: A056756 GADSDEN6 Ledb
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PAY FOR PERFORMANCE GOODYEAR Salary
Page 119 and 120:
similar positions. We want to be su
Page 121 and 122:
established by the Act help determi
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We make sure Goodyear salary ranges
Page 125 and 126:
NON EXEMPT ASSOCIATES: the new posi
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The Goodyear Tire & Rubber Company
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THE GOODYEAR TIRE & RUBBER COMPANY
Page 131 and 132:
I. DEVELOPMENTAL PROGRAM PROVISIONS
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IPAs are intended to be granted onl
Page 135 and 136:
B. Top Performance Award Policy In
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of an equal amount. A minimum inter
Page 139 and 140:
The plan is structured to provide a
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there must be at least a two grade
Page 143 and 144:
IV. Associate Performance Plan - Lu
Page 145 and 146:
* High to Low Prepared By: Total IP
Page 147 and 148:
GOODYEAR TIRE & RUBBER CO. 922 E. M
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SIGNATURE /s/ Lilly M. Ledbetter DA
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CAUSE OF DISCRIMINATION BASED ON (C
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Jul 21 11:30 1998 CP Initials _____
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AREA MANAGER BASE SALARY COMPARISON
Page 157 and 158:
Backpay for Ledbetter from 3/25/96
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A This Backpay Chart covers the tim
Page 161 and 162:
Page 163 and 164:
Page 165 and 166:
Page 167 and 168:
Page 169 and 170:
Page 171 and 172:
Page 173 and 174:
= = = JOB/SALARY = = = AS OF BASE R
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10/01/81 1,960.0200 GTR GADSDE 5500
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02/19/93 MFG001 ADVANCED LEADERSHIP
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MOBILITY-CODES WD110 WILLING TO REL
Page 181 and 182:
SALARIED EMPLOYEES MERIT INCREASE P
Page 183 and 184:
PLANT LOCATION/DEPT: MERIT BUDGET #
Page 185 and 186:
Associate Name: Lilly Ledbetter Per
Page 187 and 188:
PS#4 - Holds associates accountable
Page 189 and 190:
PS#1 - Performs housekeeping tours.
Page 191 and 192:
PS#3 - Provides feedback on perform
Page 193 and 194:
TRAINING AND DEVELOPMENTAL EXPERIEN
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1997 Reviews Name 1 Safety 2 Q&W 3
Page 197 and 198:
TIRE ASSEMBLY SALARIED MERIT PLAN Y
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RANK NAME LEVEL 1 LEVEL 2 % AMT % A
Page 201 and 202:
RAISES GIVEN BY MIKE TUCKER TO RLT
Page 203 and 204:
02/01/97 4,769.6100 GTR GADSDE 5510
Page 205 and 206:
11/16/79 1,552.7500 GT131 144 SUPER
Page 207 and 208:
06/02/00 GOODYEAR EMPLOYEE MANAGEME
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07/01/97 4,460.9300 GTR GADSDE 5500
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04/16/79 1,452.2100 GT131 5500 SUPE
Page 213 and 214:
Page 215 and 216:
09/01/97 4,371.0000 GTR GADSDE 5500
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07/01/79 1,518.0800 GT131 5500 SUPE
Page 219 and 220:
Page 221 and 222:
Page 223 and 224:
??/01/81 2.012.5200 GT131 5500 SUPE
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04/27/99 UC6005 AREA MANAGER OJT 04
Page 227 and 228:
Page 229 and 230:
??/01/81 2,018.0200 GT131 352A SUPE
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08/15/97 GD1055 MILL RESCUE—MISCE
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IN THE UNITED STATES DISTRICT COURT
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OF COUNSEL: Gordon, Silberman, Wigg
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in passenger tires, but I am not su
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A. he said the evaluation. You know
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A. Different people that I worked f
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A. No, sir, not exactly. No. the on
Page 245 and 246:
een -- and should (begin pl 146) be
Page 247 and 248:
DEPOSITION OF LILLY LEDBETTER pp. 2
Page 249:
name on the list. And she did tell
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