Respondent’s Brief
State of Minnesota in Supreme Court, Julienne Goins (Respondent) v. West Group (Appellant) [CX-00-706]
- Equal Employment Opportunity — Restatement of Company Policy
- West Group Harassment Policy
- West Group employee relocation package
- Email thread: Lewis Freeman and Julienne Goins
- Email thread: Joan Tarbox and Julienne Goins
- Email letter to multiple parties
- Email thread: Jennifer Davis and Julienne Goins
- Email thread: Janis Walworth and Julienne Goins
- Email thread: JoAnna McNamera and Julienne Goins
- Plaintiff Series of Events Journal
- Email thread #1: Tami Becker and Julienne Goins
- Email thread #2: Tami Becker and Julienne Goins
- Formal resignation from West Group and the Thomson Corporation
- Notice of client retention by Joni Thome to Thomas Moran
- Minnesota Department of Human Rights Questionnaire Package
- Handwritten notes by the Plaintiff, August 1998
- Post letter from Julienne Goins to Joni Thome
- Letter from Julienne Goins to Joni Thome, estimating Defendant liability
- Letter from Joni Thome to Julienne Goins, requesting Complaint review
- Letter from Julienne Goins to Joni Thome, with amended Complaint draft
- Plaintiff Complaint
- Defendant’s Answer and Affirmative Defenses
- Scheduling Order, Judge Franklin J. Knoll
- Defendant Notice of Taking Deposition of Julienne Goins
- Defendant’s Interrogatories to Plaintiff (Set I)
- Defendant’s Request for Production of Documents (Set I)
- Plaintiff’s Response to Defendant’s First Set of Request for Documents
- Defence deposition of Julienne Goins (Vol. I)
- Deposition correction sheet
- Defendant Memorandum of Law in Support of Motion to Compel
- Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion to Compel
- Notes from Plaintiff deposition of Jim Joseph
- Notes from Plaintiff deposition of Lewis Freeman
- Order and Memorandum by Judge Thomas W. Wexler Granting Summary Judgement Dismissal
- Statement of Account — Costs, Disbursements and Expenses
- Court of Appeals Decision
- Brief of Amici Curiae: Minnesota Employment Law Council and Minnesota Chamber of Commerce
- Respondent’s Brief
- Brief of Amici Curiae: Outfront Minnesota and Minnesota Lavender Bar Association
- Brief of Amici Curiae: National Center for Lesbian Rights, Gay & Lesbian Advocates & Defenders, Employment Law Center, Harry Benjamin International Gender Dysphoria Association
- Plaintiff notes during hearing, 3 May 2001
- Supreme Court Opinion
[ DOWNLOAD PDF ]
![Page i [Table of Contents]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.2.jpg)
![Page ii [Table of Authorities]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.3.jpg)
![Page iii [Table of Authorities]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.4.jpg)
![Page 1 [Legal Issues]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.5.jpg)
![Page 2 [Statement of the Case]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.6.jpg)
![Page 4 [Summary of the Facts]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.8.jpg)
![Page 12 [Argument: I. Standard of Review]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.16.jpg)
![Page 13 [Argument: II. The Court of Appeals Correctly Held That Goins Demonstrated Direct Evidence of Sexual Orientation Discrimination]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.17.jpg)
![Page 29 [Argument: III. The Court of Appeals Decision Is Consistent with the Legislative Intent of the MHRA and There Are No Internal Conflicts in the Law]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.33.jpg)
![Page 32 [Argument: IV. A Workable Standard Is Set Forth by the MHRA and the Court of Appeals]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.36.jpg)
![Page 35 [Argument: V. The Court of Appeals Correctly Held That A Material Question of Fact Is at Issue for Hostile Environment Discrimination]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.39.jpg)
![Page 40 [Conclusion]](https://accozzaglia.ca/wp-content/uploads/gvwg1.003.44.jpg)