Opening Brief for Appellant/Cross-Appellee - Appellate.net

apparently informed Brillman, who called Tomes less than two hours later to
complain. JA340-341.
Apart from that five-minute meeting, CGB alleged only two other acts of
interference with its at-will relationship with the therapists: (i) Tomes’ provision
of a conference room at the facility for Symphony to meet with the therapists when
Symphony came to inspect the facility prior to the starting date of its contract, and
(ii) Tomes’ statement to Symphony that one of the therapists, Michael Gasiewski,
merited a higher salary than Symphony had offered him. JA47-48.
On June 30, 1998, RHA’s in-house counsel Knaup sent a letter to CGB
reiterating that RHA had decided to terminate the contracts as a result of the
change in the Medicare regulations and that its decision was final. JA481-482. In
response to Brillman’s complaint that Sunrise had been interfering with her
employees, Knaup explained:
[W]e did no such thing, but merely informed your
employees when it was more than apparent that you had
not – that your contract was canceled effective
September 30, 1998. We did so only because our new
provider of services was scheduled to inspect the facility
and discuss arrangements with administration and staff of
the provision of services scheduled to begin on October
1st, 1998.
We asked you to do so and inform your staff, realizing
the new provider’s appearance would raise questions in
your staff’s mind, and wanting only not to disrupt service
to the residents. At no time did the facility expect to start
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