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26) Goodyear denies the allegations in Paragraph 26 of the Complaint. 27) Goodyear admits the allegations in Paragraph 27 of the Complaint. 28) Goodyear denies the allegations in Paragraph 28 of the Complaint. 29) Goodyear admits that Plaintiff was demoted from manager to assistant manager. Otherwise, denied. 30) Goodyear denies the allegations in Paragraph 30 of the Complaint. 31) Goodyear denies the allegations in Paragraph 31 of the Complaint. 32) Goodyear admits that Plaintiff filed a Charge of Discrimination with the Equal Employment Opportunity Commission. 33) Goodyear denies the allegations in Paragraph 33 of the Complaint. 34) Goodyear denies the allegations in Paragraph 34 of the Complaint. 31
35) Except to the extent expressly admitted, Goodyear denies all allegations in the Complaint. WHEREFORE, Goodyear demands a judgment in its favor and an award of its costs in defending this action. Ronald H. Kent, Jr. (KEN030) Attorney for Defendant Goodyear Tire and Rubber Company, Inc. CERTIFICATE OF SERVICE I hereby certify that I have this date served the foregoing on: Jon C. Goldfarb Susan W. Bullock Gordon, Silberman Wiggins & Childs, P.C. 1400 SouthTrust Tower Birmingham, Alabama 35203 by placing a copy of same in the United States Mail, firstclass postage prepaid and addressed to his regular mailing address, on this th day of February, 2000. OF COUNSEL 32
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 and 10: as a matter of law w/attachments fi
Page 11 and 12: 10/15/2003) 10/24/2003 NOTIFICATION
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: 18) Goodyear admits that plaintiff
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
Page 77 and 78: 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
Page 85 and 86:
A. I GUESS - WHAT ARE YOU ASKING ME
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EVER WORKED UNDER YOU, OTHER THAN M
Page 89 and 90:
A. I DON’T REMEMBER WHEN THAT WAS
Page 91 and 92:
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
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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
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similar positions. We want to be su
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established by the Act help determi
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We make sure Goodyear salary ranges
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NON EXEMPT ASSOCIATES: the new posi
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The Goodyear Tire & Rubber Company
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THE GOODYEAR TIRE & RUBBER COMPANY
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I. DEVELOPMENTAL PROGRAM PROVISIONS
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IPAs are intended to be granted onl
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B. Top Performance Award Policy In
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of an equal amount. A minimum inter
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The plan is structured to provide a
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there must be at least a two grade
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IV. Associate Performance Plan - Lu
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* High to Low Prepared By: Total IP
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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
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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
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SALARIED EMPLOYEES MERIT INCREASE P
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PLANT LOCATION/DEPT: MERIT BUDGET #
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Associate Name: Lilly Ledbetter Per
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PS#4 - Holds associates accountable
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PS#1 - Performs housekeeping tours.
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PS#3 - Provides feedback on perform
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TRAINING AND DEVELOPMENTAL EXPERIEN
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1997 Reviews Name 1 Safety 2 Q&W 3
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TIRE ASSEMBLY SALARIED MERIT PLAN Y
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RANK NAME LEVEL 1 LEVEL 2 % AMT % A
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RAISES GIVEN BY MIKE TUCKER TO RLT
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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
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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
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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
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DEPOSITION OF LILLY LEDBETTER pp. 2
Page 249:
name on the list. And she did tell
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