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To conclude this case in a just, timely manner, my client, Ms. Alice Bennett has
agreed to make the following settlement to your client. Please review this settlement
offer with your client, and respond to my office within fourteen days.
PLAINTIFF'S BACKGROUND
Ms. Bennett is a young, educated, and experienced female. She was employed by
Rikards-Hayley for four years. Throughout her tenure, she received superior evaluations
resulting in a promotion as acting manager of the training and development
department. During her position as acting manager, the department thrived under her
supervision.
MEDICAL HISTORY
Before this situation occurred at Rikards-Hayley, Ms. Bennett was a healthy
individual who did not have physical or mental health problems. She has no history of
medical diseases or treatment.
THEORIES OF RECOVERY
Ms. Bennett can recover damages under Title 42 under the EEOC for Wrongful
Discharge, Intentional Infliction of Emotional Distress, Fraud, Deceit, and
Misrepresentation, Breach of Contract, and Breach of Implied Covenant of Good Faith
and Fair Dealing.
FURTHER DAMAGES
Ms. Bennett has been unable to find work since being terminated from Rikards-
Hayley. She made a salary of $150,000 at Rikards-Hayley and is losing out on this
income. Ms. Bennett received a severance package of 6 months, but most employees
when terminated receive a full year’s pay. Ms. Bennett intends to request lost wages in
the amount of $100,000, $5,000 in medical expenses, $15,000 for pain and suffering,
and $50,000 in punitive damages.
PROPOSED SETTLEMENTS
Ms. Bennett is asking for a total of $170,000 in damages. It is anticipated that the
jury will reward the full amount due to the exhibits and proof against Rikards-Hayley.
However, to speed up the process and reduce costs, she will accept the amount of
$100,000.
This is a significant decrease in the expected recovery should the matter go to
trial. As counsel for the plaintiff, I urge you to bring this settlement offer to your client
for acceptance.
Respectfully,