Joint Appendix - LawMemo

21. The plaintiff was the only Area Manager
transferred out of the sixteen (16) Area Managers.
22. After transferring the plaintiff out of the Area
Manager position, the defendant filled her position with a
man.
23. After the plaintiff’s removal from the Area
Manager position, there were no female Area Managers.
24. The defendant’s act of forcing the plaintiff to
transfer to the Technical Engineer job was a clear intent to
cause her resignation as the Technical Engineer position
required the plaintiff to do extensive manual labor including
lifting two hundred and fifty (250) eighty (80) pound tires off
of one truck and onto another.
25. The plaintiff was the only woman in that
position.
26. Despite the grueling physical barriers the
defendant threw in front of the plaintiff, the plaintiff did her
job.
E. Disparate Treatment in Training and
Discipline
27. The plaintiff received no training for the
Technical Engineer position, and there was no job procedure
manual or written job description available to the plaintiff.
28. The plaintiff was suspended for 3 days for
allegedly making an error that similarly situated men made
and were not suspended.
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