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On or about October 4, 1996, Ms. Nield received a “Notice of
Right to Sue” from the Phoenix District Office of the EEOC.
In December 1996, Ms. Nield filed a complaint (complaint)
against Goer in the United States District Court for the Southern
District of Utah (United States District Court). In that com-
plaint, Ms. Nield alleged both a claim for sexual harassment
under “Title VII of the Act of Congress known as ‘The Civil
Rights Act of 1964' (42 U.S.C. �2000e) et seq.)”, and a State law
claim for wrongful termination “in violation of Title [sic] 35-9-
11, Utah Code Annotated.”
Ms. Nield’s complaint alleged in pertinent part:
11. During and throughout the period of Plain-
tiff’s employment with Defendant [Goer], and culminat-
ing with the Defendants [sic] termination of the Plain-
tiff, the Plaintiff was subject to sexual harassment in
violation of Section 704, Title VII (42 U.S.C. �2000e-
3), to wit:
a. The Defendant, Goer Manufacturing Company
subjected her to a hostile and sexually demeaning work
environment due to repeated acts of sexual harassment
by her supervisor * * * by subjecting the Plaintiff to
such things as:
i. comments about her anatomy;
ii. degrading sexual remarks;
iii. pressure to date and give sexual
favors to a co-worker in return for money;
iv. having sexually explicit calendars
and cartoons in the workplace; and
v. other acts and omissions of and
causing sexual harassment.
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