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ruRslrymmIN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF'GEORGIAATLANTA DIVISION
CIVIL ACTION NO.1:10-CV-2280-SCJ
Jtl3 t 2gB
LISA KARAS,
Plaintiff'
NEW NGC, INC.,
Defendant.
SPECIAL INTERROGATORIES TO THE JURY ANd VERDICT FORM
Do you find from a preponderance of the evidence:
1. That the Plaintiff was discharged from employment by the Defendant?
Answer Yes or No
2. That the PlaintifPs sex orgender was a substantial ormotivating factor that prompted
the Defendant to take that action?
Answer Yes or Nov<s
[Ng!g: If you answered No to either Question No. 1 or Question No.2you need not rnswer the remaining questions.]
3. That the Plaintiff would have been discharged from employment for submitting afraudulent expense report and not being truthful about it when confronted by her
manager regardless of the Plaintiff s sex or gender?
Answer Yes or No
Case 1:10-cv-02280-SCJ Document 119 Filed 01/31/13 Page 1 of 3
5.
That the Plaintiff should be awarded damages to compensate for a net loss ofwages
and benefits?
Yp</ '- \-l
6.
Answer Yes or No
Ifyou found that the Plaintiffshould be awarded damages for a net loss ofwages and
benefits, has it been proved that even if the Plaintiff had not been terminated on
October 7,2008, the Defendant would have terminated the Plaintiff s employment
by January 18, 201I, because it leamed that Plaintiff, at the time she was hired,
submitted an employment application and resume that knowingly misrepresented
Plaintiffas having graduated from high school with a diploma and having graduated
from Cwinnett Technical College? , /1.1Answer Yes or No /V V
Ifyour answer is No, then enter the amount ofnet loss ofwages and benefits
to the date oftrial.
Amounr s 12,1 oo0.--------
Ifyour answer is Yes, then enter the amount ofnet loss ofwages and benefits
- limiting your award ofbackpay to the date the Defendant would have made
the decision to discharge Plaintiffas a result ofafter-acquired evidence.
Amount, agW6iThat the Plaintiffshould be awarded damages to compensate for emotional pain and
mental ansuish?
Answer Yes or No
Ifyour answer is Yes,in what amount? $ /D oo 0,"
(b)
,/7 (a) That a higher management official of the Defendant acted with malice or reckless
indifference to the Plaintiffs federally protected rights?
Answer Yes or No NOIfyour answer to 7(a) is Yes, do you further find that the Defendant itself had notacted in a good faith attempt to comply with the law by adopting policies andprocedures designed to prohibit such discrimination in the workplace?
Answer Yes or No
Page 2 of 3
Case 1:10-cv-02280-SCJ Document 119 Filed 01/31/13 Page 2 of 3