What was Lydia's problem at work? (i.e., what signs are there
that she needed accomodation?)
Has Lydia made requests for accomodations?
What about termination for no cause?
Can Chuck E. Cheese protect itself just by keeping mum?
Why is costume such a burden?
Opening statements:
"Based on disability" doesn't imply scienter.
Refusing to reinstate because of EEOC claim is itself
actionable
These sorts of hearings are very informal, either through state
process or EEOC,
Punitive damages are poorly understood here?
Structuring of settlements is an art, because it can screw up
benefits. There's a thing called a "special needs trust"
that can help out here: the money goes in there, and it's
administered on your behalf.
References for future employment are also an issue: your
client has a blank spot in their resume that they have
to explain, knowing that no employer wants a complainer
(especially one who knows their rights). So you negotiate
for a neutral reference, and change "termination" to
"resignation" in that reference, if you can. File
expungement can be negotiated as well.
A settlement conference is a good place to learn the other
side's position even if you don't settle. You can use
them to figure out whom you want to depose, etc.