Jared R. and Naylene M. Nield - Page 4




                                        - 3 -                                         
               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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