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Martin was a resident engineer at DaimlerChrysler’s Assembly Plant in Fenton, Missouri. Martin received poor performance reviews for two consecutive years and was terminated by DaimlerChrysler in June 1998. DaimlerChrysler’s stated reasons for terminating Martin were poor performance and attendance. In November 1998, Martin sued DaimlerChrysler, alleging hostile work environment sexual harassment, sex discrimination, and retaliation, all in violation of Title VII. In her complaint, Martin alleged that she had suffered mental and emotional distress as a result of DaimlerChrysler’s conduct.

DaimlerChrysler served written discovery, interrogatories, and requests for documents on Martin, and took her deposition over the course of six days. In her deposition, Martin twice testified that she had never been a party to another lawsuit, specifically denying that she had been involved in any litigation while at her previous job at American Airlines. DaimlerChrysler subsequently learned that Martin had sued American Airlines in Oklahoma state court and in the Northern District of Oklahoma for sexual harassment, discrimination, and wrongful termination. Martin had retained several different attorneys to represent her in the Oklahoma lawsuits, and appeared in person at a case management conference in the federal court lawsuit.

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