Joint Appendix - LawMemo

FIFTEENTH DEFENSE
Plaintiff is not entitled to an award of punitive
damages because Goodyear made a good faith effort to
comply with Title VII.
SIXTEENTH DEFENSE
For answer to the numbered paragraphs of Plaintiff’s
Complaint, Goodyear says as follows:
1) Goodyear admits that this Court has subject
matter jurisdiction over all claims brought by this Plaintiff
pursuant to Title VII of the Civil Rights Act of 1964, as
amended. Goodyear denies that it has in any way violated
that statute, that Plaintiff is entitled to any relief and that
Plaintiff may try any claims for equitable relief before a jury.
2) Goodyear admits that Plaintiff was employed
by Goodyear in Butler County, Alabama, which is in the
Middle District of the State of Alabama.
3) Upon information and belief, Goodyear
admits that Plaintiff is black, over 19 years of age, and a
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