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Sample Briefs & Motions
- TIMOTHY LONGLEY, v. JOHN E. POTTER
- DALLAS MEDICAL DISTRIBUTORS, LTD., v. AMERICAN MEDICAL, INC.,
- PATRICIA M. THOMAS, v. LARRY G. MASSANARI
- DOUGLAS FACTORS WITH CASELAW
- EEOC GUIDANCE ON VICARIOUS LIABILITY
Closing Brief - Ms. Client vs. USPS - this is the closing argument for a case currently pending before the EEOC's Baltimore District Office. The case involves a Postal employee who is sensitive to temperature changes and who alleges the USPS did not accommodate her disability by controlling the extremely cold temperatures in her work area.
Sample Stipulation - Ms. Client vs. USPS - this Stipulation was used to avoid having to call an expert witness in the reasonable accommodation case cited above.
Closing Brief - Mr. Client vs. SSA - this is a closing Brief for a case alleging "reverse discrimination" in a non-selection case.
MSPB Appeal Brief - Rio vs. SSA - this is the Appeal Brief to the MSPB in a removal action in which the Appellant claimed that the removal was due to disability and that the Agency failed to accommodate her disability.
MSPB Decision - Rio v. SSA - This split decision in a disability discrimination (reasonable accommodation) case was appealed to the EEOC.
EEOC Appeal Brief - Rio vs. SSA - this is the Appeal Brief to the EEOC after a split decision was rendered by the MSPB.
Opposition to Motion to Dismiss - in an overtime action against the State of Maryland for Contract Employees.
Response to Show Cause - in an MSPB Appeal regarding a jurisdictional issue.