CSUN Law Sexual Harassment and Retaliation Paper – Description
Christine Connors has sued Capital Group, Inc. (“CGI”) for wrongful termination,
sexual harassment, and retaliation. Christine worked for CGI in its marketing department
from 2005 – November 1, 2014 when she was terminated, ostensibly due to poor
performance. Ms. Connors alleges that the real reason for the termination was her refusal
to succumb to William Capital’s, President of CGI, romantic advances. She alleges that
on October 15, 2014, she complained to her boss, Jon Bosman that Mr. Capital had
invited her to a “business dinner” but upon arrival at the restaurant, Ms. Connors realized
there were no clients present and that Mr. Capital intended for the evening to be a
romantic encounter. Ms. Connors alleges her termination was in retaliation for her
rejection of Mr. Capital’s romantic advances and her complaining of them to Mr.
Bosman.
Discovery has revealed that ten years prior to Ms. Connor’s employment with
CGI, she worked as a dancer in a Strip Club in Hollywood. Ms. Connors is concerned
that if the jury learns of her prior occupation, they will be prejudiced against her and not
keep an open mind as to her claims.
Trial is set for January 15, 2016 with the FSC on January 6, 2016.
Your firm represents Ms. Connors. The partner on the case asked you to prepare
the following: (1) Draft a Motion in Limine (no more than 3 pages) set for hearing at the
FSC on behalf of plaintiff seeking to exclude her employment as an adult entertainment
dancer (2) a Witness List, (3) Exhibit List and (4) Joint Short Statement of the Case and
(5) Determine when these documents must be filed. For the witness list, add the names
and titles of two additional witnesses who should testify at trial (make them up,
demonstrating creativity and understanding of the assignment). Similarly, for the exhibit
list, add one additional exhibit (make it up) that should be presented at trial.
The witnesses identified by plaintiff are: (1) Christine Connors, (2) Jon Bosman,
(3) William Capital, (4) Dr. John Expert, CPA, (5) Mellie Resource, Director of Human
Resources for Capital Group Inc., and (6) Dan Remedy, M.D. – Plaintiff’s Psychiatrist.
The exhibits are: (1) Plaintiff’s Personnel File from Capital Group Inc., (2)
Plaintiff’s W-2 Forms from 2005-2014, (3) Plaintiff’s Resume, (4) List of all Employers
where Plaintiff has applied for employment post termination, (5) Dr. Expert’s Calculation
of Plaintiff’s Damages, and (6) Plaintiff’s medical records from Dr. Remedy.
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