Plaintiff'S Amended Verdict Form

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Case 3:02-cv-02304-MRK
Document 120
Filed 09/06/2005
Page 1 of 5
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRENDA J. LEWIS,
:
CIVIL ACTION CASE NO.
Plaintiff,
:
v.
:
302 CV 2304 (MRK)
STATE OF CONNECTICUT,
:
DEPARTMENT OF CORRECTION
:
et al.,
:
Defendants
:
SEPTEMBER 6, 2005
PLAINTIFF’S AMENDED VERDICT FORM
The following proposed amendments to Plaintiff’s previously submitted proposed jury
instructions are offered solely with respect to changes required by her Trial Brief submitted
herewith regarding the question:
Whether Defendant Sousa’s relationship to Plaintiff was that of her “supervisor” for purposes of
imputing vicarious liability to her employer, Defendant DOC, under principles applicable to Title
VII is a question for the jury or the Court.
I.
As to Plaintiff’s claim against the defendant Department of
Correction, under Title VII, that she was subjected to a hostile work
environment based on race.
Do you the jury find:
(1)
That plaintiff has proved by a preponderance of the evidence that she was subjected
to unwelcome verbal or physical conduct that she subjectively perceived as
harassment creating a hostile work environment?
If “Yes” ______________, proceed to Question 2.

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