Joint Appendix - LawMemo

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A. MY ENTIRE CAREER, EXCEPT FOR THOSE LAST FEW MONTHS OF 1998 AS A TECHNOLOGIST SPECIALIST. Q. WE’VE HEARD SOMETHING CALLED AREA MANAGER. AT SOME POINT IN TIME, DID THE TITLE CHANGE? A. YES, IT WAS A SUPERVISOR. AND IN 1985, THEY CHANGED THE JOB DESCRIPTION SOMEWHAT, ADDED ADDITIONAL RESPONSIBILITY TO THE JOB, AND IT CHANGED TO AREA MANAGER AT THAT TIME. Q. WHEN THE JOB TITLE CHANGED OVER TO AREA MANAGER, WERE YOU REQUIRED TO GO THROUGH SOME SPECIAL TRAINING? [*25] A. YES, WE WERE. Q. WHAT WAS THAT FOR? A. THAT WAS IN ORDER TO PREPARE US AND HAVE US READY TO SUPERVISE THE MAINTENANCE AND ELECTRICIAN PEOPLE. Q. WERE YOU TESTED ON THAT TRAINING ON ELECTRICAL AND MECHANICAL? A. YES, I WAS. Q. HOW DID YOU SCORE ON THAT TEST IN COMPARISON TO ALL THE MEN THAT YOU WERE WORKING WITH? 35
A. WITH THE MECHANICAL, I FINISHED SECOND OUT OF ALL THE 44 TO 60 PEOPLE; AND THE ELECTRICIAN’S TEST, I FINISHED FOURTH OUT OF ALL OF THEM. AND THEN WHEN YOU AVERAGED THE TWO GRADES TOGETHER, I FINISHED SECOND. [*29] * * * * * Q. DID THE PLANT MANAGER, RICHARD ODELL, SAY ANYTHING THAT INDICATED THAT YOU WERE NOT WELCOME THERE AS A WOMAN? A. YES, SIR. Q. WHAT DID HE SAY TO YOU? A. HE SAID THAT – THAT THAT PLANT DID NOT NEED WOMEN, THAT WE DIDN’T HELP IT, WE CAUSED PROBLEMS. [*30] * * * * * Q. NAME FOR ME THE OTHER WOMEN THAT YOU KNOW OF THAT WORKED AS AREA MANAGERS WHEN YOU WERE AN AREA MANAGER. A. JOANNE FIRESTONE WAS THERE FOR A FEW YEARS. SHE QUIT. CATHY ROBERTSON, SHE WAS AN AREA MANAGER. SHE CAME ON 36
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 and 34: 18) Goodyear admits that plaintiff
Page 35 and 36: 35) Except to the extent expressly
Page 37: Q. WHERE DO YOU GO TO COLLEGE? A. J
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
Page 87 and 88: EVER WORKED UNDER YOU, OTHER THAN M
Page 89 and 90:
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
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Q. WELL, WHAT DID YOU TELL HER? IF
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A. ON THIS DOCUMENT, NO, SIR. Q. IN
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Q. BUT YOU COULDN’T TELL HER THAT
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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
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11/16/79 1,552.7500 GT131 144 SUPER
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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
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Page 221 and 222:
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??/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
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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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