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Here's the Case
A wrongful termination claim with multiple causes of action. This is what you're working with.
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Reading Your Documents
The system analyzes depositions, exhibits, and case files to extract key facts.
Applying Legal Framework
Matching case facts to applicable statutes and legal standards.
Executing Legal Command
Running the mediation brief generation with all case data.
Confidential Mediation Brief
Prepared Pursuant to Evidence Code Section 1119
All communications made in the course of mediation are confidential and inadmissible pursuant to Evidence Code Sections 1115-1128.
I. Introduction
Plaintiff brings this action against Defendant employer for disability discrimination, failure to engage in the interactive process, failure to accommodate, retaliation for protected activity, and wrongful termination in violation of California's Fair Employment and Housing Act ("FEHA"), the California Family Rights Act ("CFRA"), and public policy.1
II. Statement of Facts
Plaintiff was employed by Defendant for over five years as a Senior Account Manager. Throughout tenure, Plaintiff consistently received positive performance evaluations, including "Exceeds Expectations" ratings.2 (Exhibit F, Personnel File)
Following disclosure of a qualifying medical condition and request for reasonable accommodation, Plaintiff's performance review was downgraded despite no documented performance deficiencies.3 The PMK for Human Resources testified: "I don't recall any specific meetings about that [the interactive process]." (PMK Depo., 112:7-15)
III. Liability Analysis
Under FEHA, to establish a prima facie case of disability discrimination, Plaintiff must show: (1) Plaintiff suffered from a disability or was regarded as having a disability; (2) Plaintiff was otherwise qualified for the position; (3) Plaintiff suffered an adverse employment action; and (4) Plaintiff's disability was a substantial motivating reason for the adverse action. Sandell v. Taylor-Listug, Inc. (2010) 188 Cal.App.4th 297, 310.4
IV. Damages Summary
Economic Damages:
Past Lost Wages (18 months): $187,500
Future Lost Wages (24 months estimated): $250,000
Lost Benefits Value: $45,000
Non-Economic Damages:
Emotional Distress: $150,000 - $300,000
Punitive Damages: Available under Gov. Code 12940 where employer acted with malice, oppression, or fraud
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/jjlaw:mediation:create martinez --format both --quality-target 9.0
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