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Erin Goecke

March 23, 2018

Vanessa Graves, Esq.


Miller, Graves and Klein
1 Main St.
New York, New York

RE: Bennett v. Rikards-Hayley

Dear Ms. Graves,

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.

FACTS SURROUNDING THE CASE


After Ms. Bennett served as acting manager of the department of training and
development for about two years. Then, Rikards-Hayley decided it was time hire a full-
time, official manager of the department. Ms. Bennett was interviewed and a strong
recommendation by her immediate supervisor was given to the hiring board. The board
responded to her supervisor, Darren Blackwood, stating that male employees were
reluctant to take direction from a woman, and that they interview committee was
concerned about her physical appearance.
The interview committee instead hired Ms. Yardly over Ms. Bennett, claiming
Ms. Yardly was more experienced than someone who had been in the department for
four years. After Ms. Yardly began the manager position, Ms. Bennett was treated poorly
and harshly criticized. Even Ms. Yardly made comments about Ms. Bennett’s physical
appearance. A couple months later, Ms. Bennett was fired.
Erin Goecke

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.

INJURIES TO PLAINTIFF AND MEDICAL EXPENSES


Ms. Bennett has suffered severe emotional distress resulting in physical harm
from the harassment about her physical appearance, heavy criticism regarding her work
product, and being fired despite her effort and loyalty to Rikards-Hayley. She also
suffered humiliation from these events. To date, Ms. Bennett has incurred medical bills
in the amount of $2,500, but she is continuing to attend treatment adding more
expenses.

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,

Anthony Righetti, Esq.


AR/eg
enclosures
Cc: Ms. Alice Bennett with enclosures