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posted:
11/7/2011
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The retaliation includes:

•Her harasser refusing to speak with her and

directing others not to speak with her.

The un wanted and offensive touching includes: February 19 •He withholds important job information from her

• Touching of her hair, neck, back,

and buttocks Jane Doe reports the •He threatens her job and her future employment

• Rubbing and massaging of her neck, unwanted and offensive

touching and verbal •He subjects her to different requirements than

back and arms her co-workers who have the same position in the

• Pressing his body against hers comments pursuant to

her employer’s sexual company

harassment policy. •Another supervisor tells her that she is not

welcome and should leave

•Her co-workers refuse to speak with her and

completely ignore her.







February 17

January 1 Jane Doe is again approached by a

Jane Doe begins to experience superior in a dimly lit work room.

unwanted and offensive sexual March 3

He approaches her from behind,

touching by a superior. She is presses himself up against her and Jane Doe meets with the harasser

also subjected to unwanted and begins to rub her neck and and his assistant. She explains

offensive verbal remarks. shoulders. Jane leaves the room how she feels isolated, degraded,

quickly. and that appears to be a form of

retaliation for reporting the

harassment.









January February March

January 15

February 11

Jane Doe reports the unwanted

and offensive touching to a Jane Doe confides in a

supervisor about the March 1

supervisor

harassment Jane Doe is informed

by another supervisor

January 20 that she is no longer

February 15 welcome at the

Jane Doe’s supervisor tells company and should

Jane Doe tells another supervisor that

her that he will distribute a leave.

she may leave her job when her contract

copy of the company’s policy

is up due to the harassment.

on sexual harassment to all

employees.

Damages

Texas Labor Code § 21.2585



• Compensatory Damages

– Future pecuniary losses (not subject to the damage cap)

• By not finishing this year of her residency program,

Dr. Kite will enter private practice one year later

and suffer an economic loss of: $150,000

– Emotional pain and suffering: $75,000

– Mental anguish: $50,000

• Punitive Damages: $50,000

• Reasonable attorneys’ fees: $25, 000

________________________________________________________________

Total Sought: $350,000

• Criminal Liability

– Victim compensation fund

– Fine

• Administrative Liability

– Report to the Texas Board of Medical Examiners

Sexual Harassment Recent Jury Verdicts

• $50,000,000 in punitive damages and $35,000 in compensatory damages for hostile work

environment claim

– Kimzey v. Wal-Mart Stores, Inc.

• $8,000,000 to plaintiff from Texas jury for hostile work environment claim

– Scribner v. Waffle House, Inc.

• $2,000,000 for hostile work environment claim

– Kentucky woman suing Phillip Morris in an unreported case

• $6,900,000

– Awarded to a former employee of Federal National Mortgage Association

• Multi-million dollar settlement against Walt Disney World by three female firefighters

• $350,000 in punitive and compensatory damages and over $400,000 in fees.

– Huffman v. Pepsi-Cola Bottling Company

• $2,000,000 jury verdict due to injuries of sexual harassment including, severe emotional

distress, major depressive disorder, shame, humiliation, embarrassment and other emotional

injuries.

– Griffin v. City of Opa Locka



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