NITA Publications

Williams v. Simonson Defendants Version

Mary Anne Williams is suing the defendants, David A. Simonson, Christine Jefferson, Nita University, and The Patterson Institute, and is seeking to recover damages for gender discrimination and the tort of defamation. There are five potential claims: gender discrimination, quid pro quo sexual harassment, hostile work environment, intentional infliction of emotional distress, and wrongful termination. Williams seeks back pay, lost pay, damages, and reinstatement. Designed for advanced advocacy training, this case file involves difficult legal and factual issues for jury resolution and requires the examination of expert witnesses. There is one witness for the plaintiff and four witnesses for the defendants.

• >> TABLE OF CONTENTS
  CONTENTS
  
  DEFENDANT MATERIALS
  
  INTRODUCTION
  
  PLEADINGS
  Complaint
  Answer
  Reply to Counterclaim
  Elements of the Causes of Action Claimed by the Plaintiff
  
  DEFENDANT'S STATEMENTS
  David Simonson
  Christine Jefferson
  
  EXHIBITS
  
  Exhibit 1 Nita University Tenure Standards and Procedures
  Exhibit 2 Resume of Mary Anne Williams, Ph.D.
  Exhibit 3 Letter of February 10, 1996 to Dr. Mary Anne Williams from Nita University School of Public Policy
  Exhibit 4A-4E Yearly memos from Dean Christine Jefferson to Professor Mary Anne Williams regarding yearly reviews
  Exhibit 5A-5D Yearly letters to Mary Anne Williams from David A Simonson, Ph.D. of The Patterson Institute for Public Policy
  Exhibit 6 Letter of June 1, 2001 to Professor Mary Anne Williams from Christine Jefferson, Dean
  Exhibit 7 Letter of October 12, 2001 to Mary Anne Williams from David A. Simonson of the Patterson Institute for Public Policy
  Exhibit 8 Confidential memo dated March 3, 2002 to Mary Anne Williams from Judith Harriman regarding current work load
  Exhibit 9 Letter of April 10, 2002 to Professor Mary Anne Williams from David R. Wellman of The American Public Policy
  Exhibit 10 Memo dated May 5, 2002 to Tenurial Faculty regarding Tenure Report for Professor Mary Anne Williams
  Exhibit 11 Letter dated May 20, 2002 from Marvin Taylor, Ph.D. to Professor Mary Anne Williams
  Exhibit 12 Letter dated May 24, 2002 to Marvin Taylor, Ph.D. from Mary Anne Williams, Ph.D.
  Exhibit 13 Memo dated May 2, 2002 to Tenurial Faculty regarding Tenure Report for Professor William Vasquez
  Exhibit 14 Letter dated June 8, 2002 to Dean Christine Jefferson from Gregory Patterson, Jr.
  Exhibit 15 Letter dated June 15, 2002 to Mary Anne Williams from Dean Christine Jefferson, Ph.D.
  Exhibit 16 Letter dated June 30, 2002 to Dean Christine Jefferson, Ph.D. from Mary Anne Williams, Ph.D.
  Exhibit 17 Letter dated July 6, 2002 to Ms. Terry Mattoon from Charles R. Twiggs
  Exhibit 18 Memo dated July 8, 2002 to Nita University Committee on Discrimination from Mary Anne Williams, Ph.D. regarding discrimination complaint
  Exhibit 19 Memo dated February 12, 1999 to Nita University Committee on Discrimination from Mary Anne Williams, Ph.D. regarding discrimination complaint
  Exhibit 20 Anonymous letter to Nita University School of Public Policy
  Exhibit 21 Anonymous letter to Nita University School of Public Policy
  Exhibit 22 Letter dated November 22, 2002 to Dean Robert Verdana from Dean Christine Jefferson, Ph.D.
  Exhibit 23 Letter dated November 20, 2002 to Dean Robert Verdana from David A. Simonson, Ph.D.
  Exhibit 24 Letter dated September 15, 2002 to Dean Robert Verdana from Marvin Taylor, Ph.D.
  Exhibit 25 Letter dated April 20, 2003 to Dr. Rose Clemmons from Marvin Taylor, Ph.D.
  Exhibit 26 Letter dated May 5, 2003 to Dr. Rose Clemmons from David A. Simonson, Ph.D.
  Exhibit 27 Letter dated May 15, 2003 to Dr. Mary Anne Williams from Rose Clemmons, Ph.D.
  Exhibit 28 Expert Economics Witness for the Defense--Denise Morris, Ph.D.
  Exhibit 29 Expert Economics Witness for the Plaintiff--Brian Sullivan, Ph.D.
  Exhibit 30 Economic Loss Analysis by the Defense
  Exhibit 31 Economic Loss Assessment by the Plaintiffs
  
  JURY INSTRUCTIONS
  
  SPECIAL VERDICT FORM
  
  SUPPLEMENTAL MATERIAL
  • Five Ways to use a Deposition at Trial
  • Problems In Dealing With Opposing Counsel at Deposition
  • Attachment to Problems in Dealing With Opposing Counsel (Select Federal Rules of Civil Procedure)
  • Arthur J. Hall, Plaintiff, v. Clifton Precision, A Division of Litton Systems, Inc.

• >> AUTHORS
  
  
  • Anthony J. Bocchino
    
    
    • Professor Anthony Bocchino is an honors graduate of the University of Connecticut School of Law after which he was a Bradway Fellow at the Duke University School of Law. He served as a full time faculty member at both the University of Connecticut School of Law and the Duke University Law School before joining the Temple University Beasley School of Law faculty in 1979. At the Beasley School of Law for the period 1979 -1989 he was Director of Temple's Trial Advocacy and Clinical Programs. He has designed the program, written materials and taught in the law school's Integrated Trial Advocacy Program which has been twice awarded the Gumpert Award for Excellence in Teaching Trial Advocacy from the American College of Trial Lawyers, in addition to receiving the Gambrell Award for Teaching Professionalism from the American Bar Association. In 1997 he was named by Temple University as the Jack E. Feinberg Professor of Litigation.
      
      Professor Bocchino has been honored with teaching awards from Duke University School of Law where he received the Mordecai Society Award and the Beasley School of Law where he was the first recipient of the George P. Williams II Memorial Award. In addition, he has received the Oliphant Award from the National Institute for Trial Advocacy and the Richard S. Jacobson Award from the Association of Trial Lawyers of America for excellence in teaching the art and science of trial advocacy.
      
      In addition to his law school duties Professor Bocchino has served as a faculty member for the National Institute for Trial Advocacy (NITA) since 1974, served as NITA's Director for five years and served as the organization's Editor in Chief. Bocchino has written materials and designed programs for trial, deposition, fact investigation, motion practice and appellate advocacy programs for more than 30 law firms and numerous public agencies. He has also conducted needs analyses and designed litigation skill curricula for numerous law firms. His CLE materials and program designs are among the most frequently utilized by those organizations. In addition, he has and will customize materials to the specific needs of individual clients.
      
      Professor Bocchino is the author of over 60 books and articles, predominantly in the fields of Evidence, Trial Advocacy, Civil Litigation and Professional Responsibility. His trial advocacy and/or deposition practice materials are used in a majority of the law schools in America, as well as in CLE litigation skills training in the public and private sectors.
      
      Professor Bocchino has been elected as a member of the American Law Institute, and named a Fellow of the American Bar Foundation, Litigation Counsel of America and the International Society of Barristers.

  
  

  • David A. Sonenshein
    
    
    • David A. Sonenshein is the I. Herman Stern Professor of Law at Temple University. He has also been a faculty member at George Washington University National Law Center, DePaul University College of Law, and Boston University School of Law, teaching civil procedure, criminal procedure, evidence, professional responsibility, trial advocacy, and complex civil litigation. He has received the Outstanding Professor Award at both DePaul and Temple Law Schools a total of six times. He is a nationally recognized lecturer on the law of evidence in the courtroom. As a consultant to the Federal Judicial Center, he leads seminars for all new Federal District Court Judges on the law of evidence, as well as offering seminars for experienced U.S. District Court Judges. He has served as an instructor on evidence and trial advocacy for NITA, AILTO (of which he is the Director), ALI-ABA, and the National Practice Institute. Professor Sonenshein earned the Francis E. Rawle Award from the American Law Institute and American Bar Association for his outstanding contributions to the field of post-admission legal education. He received his B.A. from Cornell University and his J.D. from New York University School of Law.