Subject: Statement Position Statement
In Re: EEOC No. 530-2021-00005X
Agency No. 63-2020-00084-D
Dear Hon. Santiago-Flores,
I hope this email finds you well. This email seeks to update you on the parties’ settlement position in the referenced case.
On November 17, 2021, I sent the Respondent U.S. Department of Commerce a Settlement Demand Letter (“the letter”). In the letter, I demanded the following terms for the settlement:
- Settlement amount: $225,000
Itemized as follows:
General damages: $185,000
Compensatory damages: $100,000
Interim Fees: $5,000
Costs of the Suit: $10,000
Miscellaneous Issues/Expenses: $5,000
- In addition to the said amounts, I requested for an equitable relief, to wit, the Respondent expunges from its record, any adverse material regarding its discriminatory employment practice.
- The General damages demanded are inclusive of the Front pay and Back pay, each of equal amounts.
- The Compensatory damages are inclusive of future and past pecuniary damages, and non-pecuniary damages.
Your Honor, it’s also worth noting that the demanded amount is lesser than the actual damage in the event the Respondent does not accept the Settlement Offer. Accordingly, this Offer contains no provision that is subject to flexibility.
That notwithstanding, the Respondent has failed to give a concrete response to the Settlement Offer. I am convinced I have a valid case against the Respondent. Therefore, it appears the Respondent has not appreciated the good terms of the Offer, which would have them pay lesser damages had this case proceeded to hearing.
Thank you for attention to this matter.
Melody J. Rodgers
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