USA: +1(669)289-8683 
Sign in
DB-FPX8410-
Assessment 4: Propose Preventative Measures to Avoid Legal Liability
Assessment 4: Propose Preventative Measures to Avoid Legal Liability
Write a 6-8 page paper analyzing a specific liability from your critical incident analysis and recommending measures that would have reduced the company’s liability.
Introduction
As a consultant for CapraTek, you have analyzed 30 worker complaints and focused on the specific legal liability surrounding the wrongful death complaints.
For this assessment, you will:
- Select a particular legal liability to CapraTek that arises from one of the remaining letters (other than the wrongful death complaints).
Propose preventative measures that could have avoided legal liability for CapraTek.
Preparation
For this assessment, you will analyze one of the employee complaint letters and assess the legal issue and liability it presents.
Instructions
Refer to the
CapraTek Employee Complaint Letters [DOCX]
. Select a complaint letter that presents a serious, viable legal issue other than a wrongful death complaint. Do not select a complaint that poses little or no liability to CapraTek. To potentially meet the Distinguished criteria, select a letter that suggests more than one type of legal liability; for example:
- Sex discrimination and retaliation.
- OSHA violations and ADA liability.
- Racial discrimination and age discrimination.
Religious discrimination and national origin discrimination.
Note that the letter does not need to specifically mention multiple liabilities. Even when a letter describes only one type of liability, if the complainant is in a protected class, this suggests that any formal claim is likely to allege discrimination as well.
Analyze the complaint(s) and associated liability. Develop recommended measures that could have reduced liability for CapraTek. In formulating your analysis and recommendations, include the following:
- Summarize salient facts alleged in a complaint letter identifying viable legal liability exposure for a company.
- Describe associated U.S. laws or regulations and how they are relevant to the identified liability.
- Discuss the potential harm to the company, its employees, and its workplace culture that could result from a lawsuit emanating from the selected complaint.
- Propose multiple realistic preventative measures that could have avoided legal liability using objective and fact-based arguments.Identify the individuals and departments that would need to be involved in the proposed measures.
- Suggest viable legal defenses the company could assert in a litigation context in order to defeat the complainant’s claims, including a rationale for use of the strategies.Use insights from the interview transcript to think of defenses CapraTek might wage against the plaintiff’s allegations. Legal defenses typically involve a challenge to the allegations themselves, any contribution to the incident on the part of the employee bringing the case, a lack of credible evidence, or other potential factors beyond the control of the employer.
- Analyze the ethical implications of the scenario and suggest measures that address ethical issues.Apply a recognized ethical code or framework and clearly connect the conduct to ethical principles.Convey purpose, in an appropriate tone and style, incorporating supporting evidence and adhering to organizational, professional, and scholarly writing standards.Adhere to conventions for spelling, grammar, sentence structure, legal/business terminology, and word usage.Adhere to writing conventions and APA citation and referencing.
Additional Requirements
As you complete your assessment, be sure it meets the following guidelines:
- Written communication: Use error-free doctoral-level writing, with original (non-plagiarized) content, logical phrasing, and accurate word choices.
- Scholarship: Use 5–6 professionally reputable sources to support your main points and analysis. Be sure to include scholarly sources. Course readings may be included among the required sources.
- APA formatting: All resources and citations should be formatted according to current APA style and formatting guidelines.
- Length: 6–8 typed, double-spaced pages, in addition to the cover page, illustrations, reference page, and appendix.
- Font and font size: Consistent, APA-compliant font, 12-point.
Please also note:
- For this assessment, you are required to follow the Standard Naming Convention requirements and the Track Changes requirements for any files you upload. You will find the requirements on the DBA Submission Requirements page.
- Before submitting your assessment, you are required to use Recite to check that your in-text citations match the reference list at the end of your assessment. Recite also checks for stylistic errors related to referencing. Make any corrections to your assessment based on the Recite report.
Competencies Measured
By successfully completing this assessment, you will demonstrate your proficiency in the course competencies through the following assessment scoring guide criteria:
Summarize salient facts* alleged in the letter, identifying viable legal liability exposure for a company.List associated U.S. laws or regulations and explain how they are relevant to the identified liability.Discuss the potential harm to the company, its employees, and its workplace culture that could result from the lawsuit.Propose several realistic preventative measures that could have been used to avoid legal liability.Use objective and fact-based argumentsIdentify the individuals and departments that would need to be involved in the proposed measures.Suggest possible, viable legal defenses the company could assert to defeat the claims and explain why the defenses might prevail.Use insights from the interview transcript to think of defenses – challenging the allegations; contribution to the damage by the complaining employee; lack of credible evidence; factors beyond the employer’s control, etc.Apply a recognized ethical code or framework and clearly connect the conduct to ethical principles.This Assessment has 6 parts.Be sure your paper has 6 parts!For this Assessment, you willSelect one of the complaint letters that presents serious, viable legal issues other than a wrongful death. The allegations in the letter should lead to more than one type of legal liability, such as Sex Discrimination and Retaliation or Racial Discrimination and Age Discrimination.HINT – 6. Analyze the ethical implications of the scenario and suggest measures that address ethical issues.Use error-free, doctoral-level writing.Use 5–6 professionally reputable sources to support your mainpoints and analysis.Use correct APA 7 formatting.Use as many pages as are necessary (6–8 pages, in additionto the cover page, reference page, and any appendix).Use Recite.*Blacks Law Dictionary defines salient facts as those that are “noticeable or obvious, easy to see and visible.” They are the facts that it is necessary to know in order to make a judgment on the plaintiff’s claims.
Resources: Employer Incident Response
McWilliams, P.L. (2020).
Employment law implications of a refusal to work due to fear of COVID-19
. Employee Benefit Plan Review, 74(5), 6–9.
- This resource offers practical suggestions for how an employer can respond to COVID-19 legal requirements.
Porter, N. (2019).
A new look at the ADA’s undue hardship defense
. Missouri Law Review, 84,121–176.
- This article explores defenses to ADA discrimination allegations. It explains that an employer is not required to accommodate a worker’s disability if it would impose an undue hardship on the employer.
CapraTek Employee Complaint Letters
Note: The first letter is only included as a sample. You can see analysis of this letter in the Sample
Chart provided with this assessment. You do not need to include this letter in your assessment.
Jacinta Andrews
752 Kingstruff Rd.
Birmingham, AL 35203
United States
October 7, 2020
Mr. Anthony Tsu
Director of Human Resources
The Manufacturing Center
1243 Lenox Rd., Ste. 150
Blountsville, AL 35031
Ref: Unsafe Workplace Conditions
Dear Mr. Tsu,
I am writing to you to express my extreme disappointment regarding the continued and daily workplace
negligence that I am forced to endure at my office. I am proud to play a crucial role as one of the software
engineers within the firm. But most importantly, I am 7 months pregnant. Due to a condition of my pregnancy, I
am critically vulnerable to the risk of infections, and my primary concerns are the extremely unsafe conditions
because of a lack of sanitation standards.
During the pandemic, there is an especially high demand for computer & software virtual assistance, and
fittingly there is an extra amount of stress at the office. But what disappoints me is that there is no effort to
maintain cleanliness and sanitation, even in light of the Covid-19 outbreak.
To point out the most critical and unacceptable issues: a non-operating air conditioner, “chemically”
contaminated drinking water that has an unusually strong smell and taste, and filthy, unmaintained restrooms.
The restrooms are so poorly maintained that they are unbearable to be around, not to mention for those of us
who must use them.
To highlight the lack of preparedness and failure to follow current guidelines, a colleague tested positive for the
virus today while she was at work. Earlier in the day and prior to leaving the office, she visited the restroom.
Even after her diagnosis was made clear to the administration, and word spread around the office, there was no
announcement or effort to sanitize the workplace, not even to sanitize the restrooms until after hours, exposing
all employees to Covid-19.
I am very passionate about my job, but when I complained about these conditions to the manager I was mocked.
The Supervisor even said: “You are going on maternity break soon, so why not leave now. I have more important
things to deal with than getting the air conditioning, or water supply issues fixed.”
So, I ask you… If not now, when? I am risking my and my baby’s life working hard to accomplish the company’s
goals, and this is how I am treated? It is extremely unprofessional to mock a pregnant employee over her
concerns, and I request you take immediate action to get these conditions fixed. If something happens to me or
my unborn child, or if I catch the virus, I will hold the company responsible.
Yours sincerely,
1
CapraTek Employee Complaint Letters
Jacinta Andrews
Note: All of the letters from this point on should be included in the analysis for your assessment.
Maryanne Kahlil
821 Westfield Highway
Fort Depot, AL. 36032
United States
January 15, 2021
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL. 35031
Ref: Hostile Workplace Conditions
Dear Mr. Tsu,
I have been employed at this branch of The Manufacturing Center since January of 2020 as an Analyst in the
R&D department. It is with a heavy heart that I share my grievance with you regarding the perceived hatred
towards me, based on my religion, by the management of this branch.
From day one I believe that I have been looked down upon for wearing a headscarf, which is a customary
practice of my faith as a Muslim. At first, because there has been no explicit expression of the hatred towards
me, I thought I was perhaps imagining this. But my doubt turned to certainty when, with the outbreak of
Coronavirus cases I was called in by Eric Andrews and informed that my health insurance will not be renewed.
He actually said to me: “You’re a Muslim? You go to congregations where there is no social distancing and there
are important religious events where you meet many people. We are sure you will catch the virus from one of
these events, so unless you sign a written agreement that you will not attend any such religious gatherings, we
cannot renew your health insurance. It is insane to renew the insurance for someone who knowingly put others’
health in danger.” I thought to myself, is this a joke? Clearly, he has indicated that I will deliberately put others’
lives in danger to follow my religion. To say that his remarks are insulting, is a gross understatement. Rather I
believe it to be illegal, and against my rights under the protections of freedom of religion.
With the prevalence of this virus, everyone’s life is in danger irrespective of what faith they follow. Mr. Andrews
didn’t let go of this opportunity to propagate Islamophobia. Facing racism in the name of religion is nothing new
for me, but not in the workplace, and this time all limits were crossed.
In a time of such a critical crisis, when people who are forced to remain in the office, because we are deemed
essential, and are at heightened risk of either contacting the virus or even dying, the administration department
is denying renewing my health insurance? And blaming my faith as a justification? This is wrong on so many
levels!
I demand that you investigate this matter as a violation of my rights, and clearly that you allow my health
insurance to be renewed.
Yours sincerely,
2
CapraTek Employee Complaint Letters
Maryanne Kahlil
3
CapraTek Employee Complaint Letters
Thomas Lee
801 Logan Drive
Birmingham, AL 35289
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Racial Discrimination Complaint
Dear Mr. Tsu,
I am writing to express my displeasure at the company, for which I have worked for just a few short weeks as a
security guard. My first view of the company was that it was a great place to work. I was initially congratulated
for performing my job duties exceedingly well, and I enjoyed doing my functions.
However, I have just learned that several persons have died from exposure to Covid-19, as a direct result of the
lapse in judgment and preparedness by the company. If that is not bad enough, apparently, I am being singled
out by other employees as the cause, because of my ethnicity. I may be Asian (Chinese) by origin, but I am
American citizen who has lived in Alabama nearly all of my life and have never even left the state. Not that I
should have to even make excuses to justify myself.
I am horrified that I am now a victim of discrimination on a daily basis amongst the staff. I was blatantly told by
other staff members that I brought the disease to the organization. I had reached out to my supervisor Ms.
Hernandez, but she would not listen to me. Furthermore, Ms. Hernandez continually comments on my ethnicity
and appearance and even questions me about my customs and beliefs. This is my supervisor? I don’t understand
how such behavior can be tolerated at the company.
Because of his lack of leadership, I am constantly being harassed at work. Yet management does nothing to
condemn the behavior or protect me. Rather they encourage it. Other workers have commented on my
appearance. They openly question my eating habits and what I choose to eat. They hurl insults at me throughout
the day, etc. Persons are sending negative messages via text, email, telephone calls, my social media and I am
suffering anxiety and depression because of this. The workplace is hostile and intimidating.
I have reached out continuously to the management team and HR verbally, but there is no solution. Since
speaking out, my “friends” have stopped talking to me, and the supervisor has placed me on probation. This is
just not right!!
I am reaching out to you here to have this addressed, or I will have no choice but to contact my attorney.
Yours sincerely,
Thomas Lee
4
CapraTek Employee Complaint Letters
5
CapraTek Employee Complaint Letters
Karen Small
752 Hoyt Street – Apt. 752
Birmingham, AL 35211
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Complaint Regarding Lost Wages
Dear Mr. Tsu,
Thank you for reviewing my letter. I have heard that you are a fair and just person and I am writing to you in
hopes that you can fix the mess that happened to me at work.
I am one of the frontline security officers at the plant who was diagnosed with the Coronavirus. As a frontline
worker I was made to continue my employment during the pandemic; at one point I had several symptoms and
became terribly ill. I believe that I acquired the disease from Tom Lee, the other guard on my shift that the
company allowed to spread the disease. He is from China.
Because I was forced to work, my sickness was the fault of the company, but I received no wages for the time
that I was off. My hospital bills are enormous, and I cannot pay them. I believe since it was your fault for having
this person in the company and spreading the disease, I should have some sort of compensation for my hospital
bills.
I also draw attention to the fact that there was no social distancing or mandated wearing of masks for the
workers left in the office. It is obvious the company only believes that long-standing workers should have
protection by letting them work from home.
I am upset that I was not paid for the time off and that management has informed me that my medical bills are
my own responsibility. They told me I could not have contracted the disease on the compound. How do they
know that?
This treatment by the company is ridiculous. I thought the company would care more about me. I would like you
to provide back pay for the time that I missed at work, and to pay for my medical bills. I would also like you to
fire the guy who is responsible for getting me sick. If you do not help me, I will quit and find a lawyer to
represent me.
Yours truly
Karen Small
6
CapraTek Employee Complaint Letters
Heather Brown
111 Adams Court
Birmingham, AL 35211
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Workplace Complaint
Dear Mr. Tsu,
I am employed as a janitor with the company. I have been on the job for over two years now. So far, I have really
enjoyed my work, and have no complaints about the job, or the people.
I’ll admit that working as a frontline worker is challenging, but in this COVID-19 environment working the roles
of two persons is incredibly stressful and taxing on my body. The other janitor on my shift has been fired, and
having not replaced them, the boss has given me the responsibility to keep the workplace clean and sanitized by
myself. Having to do the work of both people is extremely difficult to manage.
I am not the only person with this experience. It can be seen clearly all over the plant. There has been
resignation of employees, many are on sick leave due to COVID and unfortunately there have been a few deaths.
This has led to a significant decrease in the staff count. Is management not seeing this? Does management even
care?
Management seems reluctant to hire new staff as you believe that it will affect your pockets. But I believe that
this is unfair. You must manage the workload of your employees. Our effectiveness is being reduced because we
cannot adequately work under these conditions. But even worse is that we come to work every day and risk our
own health, our own lives, and the lives of the people at home. We wonder who will be next? Will I be the one
to get sick and possibly die?
This attitude of the company is exploitative. This overload of duties can lead us to face serious health issues. My
co-worker should never have been fired for what she did. Instead of showing leniency and regard for the
conditions which we are faced, you only want to offer strict warnings and not understand the conditions of your
employees.
I request that you consider this issue and come up with a serious and long-term solution. We just cannot
continue to work under these conditions.
Thank you,
Heather Brown
7
CapraTek Employee Complaint Letters
Leah Parrish
1254 Swamp Road Dr, – Apt, 125
Vauxhall, AL 35213
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Salary Reduction Complaint
Dear Mr. Tsu,
As a front-line worker in the Manufacturing Center, I have been asked to continue to come to work every day, as
if nothing has happened. As if there is no pandemic threatening the safety and lives of any of us.
But I am sad to say that I am an example of the danger of being an essential worker. I caught the disease from a
co-worker because I continued to come to work as I was told. When I got sick, I was out of work for three weeks
while recovering, without a paycheck.
As if the disease wasn’t traumatizing enough, not to mention having ridiculous hospital bills and being away
from my family—but when I returned to work this week, I learned that I am now facing a sudden decrease in my
salary.
There was no prior communication to any of the staff that there would be a salary cut. Are you too afraid to speak
with us? You made this disease run rampant in this organization with treacherous results. Friends and colleagues
have died, others are still sick, and the business is only protecting itself by cutting people’s pay? You only care
about your bottom line and not the workers who still rallied on for you. How could you cut our salaries like this?
I believe that I suffered from the COVID-19 infection as a result of a lapse in judgement and failure to protect the
employees, because of the owners and management of the company. These actions are causing serious trouble
for the livelihood of myself and the other employees. We are faced with the fear of contracting the disease, a
poor working environment that does not follow standard procedures to keep people safe, and now our salaries
reduced by as much as 50% for some people.
I am facing many issues due to this salary cut, at this point I cannot even buy groceries for my family. It is unfair
and wrong. The only option that has been offered to me from management is to work extra shifts to compensate
for the lost pay. That puts us at even greater risk! Why are we being exploited this way? Why should we suffer like
this?
I request you to look into this matter immediately. We need our full salaries now more than ever. I want you to
know that I have reached out to our trade union representative to get the union involved. I have also consulted
with an attorney. We need to be paid and we need to be communicated with. It’s only fair for all employees to be
treated properly.
Sincerely, your disgruntled employee and Covid-19 survivor.
Leah Parrish
8
CapraTek Employee Complaint Letters
Christopher McCoy
1254 Swamp Road Dr, – Apt, 125
Vauxhall, AL 35213
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Workplace Safety Concern
Dear Mr. Tsu,
As a worker in the customer service department, I would like to bring your attention to an issue that
has come up over the past several weeks.
The work environment is not suitable for those of us who must continue to come to work daily. As
essential workers, we do our best to come to work in light of the challenges that we face, because of
the coronavirus. The least the company can do is provide a safe space for its employees. One where
standards and precautions are in place that comply with the advice from the Centers for Disease
Control, or whatever jurisdiction we fall under.
The issue is mostly the workspace. We all work out of the typical office cubicle. The spacing and
proximity of the cubicles were feasible in the past when team meetings and frequent collaborations
were allowed. But now, with the need to social distance, remain separated by minimal distance and
wear PPE, etc., the set-up is just not safe.
Most especially now that many of our co-workers have gotten sick, it is more important than ever that
we find a way to social distance, if we are expected to continue to work at the office. Simple steps that
will help with keeping workers safe and healthy as the pandemic continues.
I have spoken to the supervisor about this, but as usual they are deaf to the concerns of the workers.
When will any of our concerns be taken seriously? Someone must step in and demand that a basic
level of health and safety standards be implemented, because our local management is not taking it
seriously.
COVID-19 is spread between close contact of persons. If we continue to be boxed up in the office, then
all of us will catch this disease. It is not rocket science. The company has been lucky that no employees
have yet died as a result of the disease, but it is only a matter of time.
I implore you to investigate this matter and find a solution as soon as possible. If there is no
immediate improvement to keep me or my co-workers protected, I will be contacting my lawyers and
the local press.
Thank you,
Chris McCoy
9
CapraTek Employee Complaint Letters
10
CapraTek Employee Complaint Letters
John Kowalski
1211 Branch Waterway
Vestavia Hills, AL 31201
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Failure to Cover Medical Expenses
Dear Mr. Tsu,
With all due respect, being a frontline manager at the company for the past seven years, I believed that the
company would be there for me during a critical time of need. However, the trust I put in the company was
utterly wrong.
Last month I contracted the coronavirus on the company compound, after coming into continued contact with a
co-worker who later tested positive. The co-worker and I shared a shift, and a post prior to their diagnosis, and
shortly thereafter I too tested positive.
I spent nearly three weeks in the hospital facing a life and death situation. My condition was critical, as a highrisk individual and thus, I was admitted to the ICU for 15 days. I am grateful that I fully recovered, but with my
recovery came large hospital bills, because my insurance plan includes a very large deductible and out of pocket
expense, as we did not plan for an event like this.
Being an employee of our prestigious company, I believed that the company would help me bear the burden of
missed work time and growing medical expenses. But I have been extremely disappointed by the company’s
stance on the matter. According to management, the company’s point of view is that it cannot be proven that I
contracted the virus while at the workplace, and therefore have refused to cooperate or offer any
compensation.
Yet many employees have contracted the coronavirus from other staff members. Even after testing positive for
the infection, sick employees were repeatedly called by the company to return to work. Thus, I believe that
legally the company is the one who should pay for my bills and should offer some form of compensation. At a
minimum, pay my insurance deductible and out of pocket expenses.
This is a very difficult situation for me. I will suffer a great deal paying my hospital bills. As this was a workplace
incident, I insist that I be compensated by the company for the costs related to my illness. Please contact me to
discuss how we may come to a solution.
Thank you in advance,
John Kowalski
11
CapraTek Employee Complaint Letters
Anonymous Essential Employee
The Manufacturing Center
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Senseless Death of Fellow Employees
Dear Mr. Tsu,
I am offering this letter as a warning to the company!
The company has allowed the Coronavirus to run rampant in the manufacturing center and does not
care about consequences.
Many of my co-workers have contracted the disease. Other co-workers have died. Still, the company
does not care about us. The company does not even care enough to make simple changes to the
workplace. They still demand that we come to work and risk our lives every day without regard for our
well-being.
Is this how the company operates? Is this how the company cares about its employees? Should we care
about you? Do you care how our friends suffered? Hooked up to ventilators unable to breathe. Unable
to be with their families. Unable to see their loved ones for weeks on end. Alone on their death bed!
The company is responsible for these people. We have been mistreated, our salaries stolen from us,
our jobs taken from us, others forced to work in an infected office. We have been victims of your
negligence, and your actions are criminal.
Mark my words. We will seek justice for our fallen friends who have died for this company, without any
care or assistance from the Manufacturing Centre. Soon you will lose your jobs and pay for your
wrongs. Soon you will know the cost of the sins you have committed.
Signed,
Anonymous Employee of the Manufacturing Center
12
CapraTek Employee Complaint Letters
Keena Quan
810 Main Street
Long Island, NY 11724
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Wrongful Death of Employee Bhashar Quan
Dear Mr. Tsu,
On September 5, 2020, at approximately 11:00 a.m. my father, Bhashar Quan, an employee who recently joined
your company at the Alabama manufacturing plant, died after contracting the COVID-19 virus from working with
you. My father was elated after not working for a while, that he was able to secure a job at a prestigious
computer parts manufacturer. He had recently lost my mother, and was getting depressed. We were happy that
he found a job he liked. We would not have imagined that just two weeks into working at your organization that
he would contract the virus and die such a terrible death, alone in a hospital.
I live in New York and every night my father would call and tell me about how your company did not take the
disease seriously. I told him to be always vigilant, as living in New York I had experienced how easily COVID-19
had wrecked families, stalled businesses, and led to thousands of deaths.
I listened to him but found it hard to believe that the company would be so sloppy with social distancing, the
simple wearing of masks, sanitizing of surfaces and allowing breaks for washing hands. When he said that people
he worked closely with were showing symptoms of the virus and that a few workers had tested positive, I
begged him not to return to your business, but by then it was too late. He started to lose his sense of smell and
taste, developed a fever and a terrible cough and within two days was admitted to the hospital, and died.
I remember my father as a provider, a man of integrity, and a person who would give his all to ensure persons
were happy. This man was taken away from us because your company would not put measures in place for the
safety of its staff. Measures that are mandated by law for all businesses. It seems my father died due to your
extreme negligence. I visited the plant recently and in speaking with other employees, what he described to me
is still happening. There is no PPE, no social distancing, there is nothing. Could you not learn from my father’s
death?
Your business intentionally contributed to my fathers’ untimely death. As a result, I am claiming the below
amount as a settlement for my father’s wrongful death. If I do not hear from you within 10 business days, I will
have no choice but to contact an attorney and file full charges of wrongful death against your company.
Pain and Suffering
$2,000,000.00
Funeral and Burial Costs
$ 15,000.00
Total
$2,015,000.00
Sincerely,
13
CapraTek Employee Complaint Letters
Ms. Keena Quan
14
CapraTek Employee Complaint Letters
Simon, Simon & Simon
54 Bayou Ave.
Tuscaloosa, AL 36055
United States
October 7, 2020
Mr. Anthony Tsu
Personnel Director
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Blountsville, AL 35031
Ref: Wrongful Death Claim – Michael Haskill
Dear Mr. Tsu,
As I notified you on September 30, 2020, my client Jefferson Haskill is seeking damages in the wrongful
death of his father, the decedent Michael Haskill, for the fatal accident caused by your workplace
negligence on September 2, 2020.
On the night in question, Michael Haskill had been working in the warehouse at your Manufacturing
Distribution Center. At approximately 11:30 p.m. an employee, Employee X, was driving a forklift
through the warehouse at a high rate of speed, and without proper safety measures, striking Mr.
Haskill, killing him instantly.
It has been determined that Employee X was operating machinery without the proper certifications,
required of all warehouse staff. When questioned about this incident, he stated that he was a new hire
who had only been on the job for under one week and had not yet been certified to use the forklift.
Employee X was instructed to do so by his supervisor, Employee Z, as the company was short-handed
due to the large number of employees who are on sick leave due to Covid-19.
Michael Haskill was Jefferson Haskill’s father, and only living relative. The younger Mr. Haskill spent all
of his free time with his father and remembers him as a generous, caring, and loving father who will be
greatly missed.
As determined by the feelings expressed by Jefferson Haskill, as well as the total expenses incurred by
the estate of Michael Reed, the requested compensation for this wrongful death claim are itemized
below.
Funeral Expenses: $8,000.00
Pain and Suffering of the Decedent: $950,000.00
Pain and Suffering of Beneficiary: $1,000,000.00
TOTAL: $1,958,000
Sincerely,
Derrick Simon
Simon, Simon & Simon – Attorneys at Law
15
CapraTek Employee Complaint Letters
16
CapraTek Employee Complaint Letters
Thomas Edwards
260 Bridgeview Hall
Savannah, GA 31401
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Age Discrimination Claim
Dear Ms. Martin,
I am in dire need of your attention regarding the issue of my forced early retirement. I have loyally served this
company for the last 20 years as a Quality Assurance Director. I am now being pushed to retire early as the
company is “downsizing” and they want to keep those employees who can adapt to new technological changes.
As I am 59 years old, I believe that I am being discriminated against based on my age.
As you know, the pension plan allows one to retire at age 65, and I would like to continue working to add value
to my pension. I do not want to let go of this job. I could’ve accepted this decision if this was it and I were to be
compensated accordingly, with a severance, and ability to draw an early retirement, but no! Recently an email
was generated that no compensation or pension payment can be provided until and unless additional pandemic
relief is approved. This is reasoned with the statement that the company is not making enough profit and may
incur a deficit if not properly compensated right now. IE: Bailed Out! It sounds to me that the pension fund has
been mismanaged, and now they are using the pandemic as an excuse to lay off its most vulnerable employees,
even though the company message is that they are downsizing due to a slowdown from the outbreak of
Coronavirus.
This is a serious issue, and I am not the only one dealing with it. There are other employees in their late 50s and
early 60s too, who have been chosen for lay-off, or early retirement. The company is being inconsiderate
towards its honest, loyal, and long-serving employees. I have spent half of my working life here and when it is
time to leave, I want to do so with dignity. I believe the company is only thinking about itself.
Will you tell me in this time of pandemic where will I find a job? I cannot adapt to the technological changes as
quickly as a young employee, but I am learning. Also, no company is hiring now where I could apply. If I lose this
job in the ongoing situation without any compensation, I will be facing severe consequences.
I request that you consider my complaint and get this issue sorted as soon as possible. I do not wish to hire a
lawyer to represent me in a discrimination claim, but I will if I am forced to.
Yours sincerely,
Thomas Edwards
17
CapraTek Employee Complaint Letters
Mona Sims
191 Evergreen Garden
Athens, GA 30601
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Gender Discrimination Claim
Dear Ms. Martin,
I am writing to you to seek your help in a recent issue that has worried me. I expect once you read my case, you
will be compelled to address the problem. I work as a technical assistant in this company and am being targeted
in the workplace because of my gender. This company was well known for providing equal rights to all genders
in any and every circumstance, and that is what attracted me to company. However, what I am experiencing
now, is the exact opposite.
Recently, when the Coronavirus challenge came to pass, employees were understandably tense about changes
in company employment policies that could potentially result in health & safety issues, wage reductions or even
loss of employment. Gladly, being a computer manufacturing company and the world shifting to virtual systems,
our business was among the lucky few that has remained viable.
Irrespective of the bottom line, there were heavy pay cuts enacted. However, as I have come to learn, not for all,
but only for our female employees. As you are likely aware, since February we have taken a salary reduction of
30%. I and a handful of other female employees complained about our wage reductions to the Finance
Department, but to no avail. They gave a vague response that all employees are suffering because of the losses
the company has faced. All things considered, this silenced us for the time being.
However, last week, when I was talking about the wage cuts with a male colleague, he was unaware of it. To my
surprise, he never experienced any such salary deduction and even showed me his pay check. I inquired with
some other male colleagues, and they all had the same response.
I gathered the female employees and went to the Finance Director Mr. Silvester. His response was quite
troubling. At first, he rejected our inquiry. However, once he realized we had corroborating evidence, he stated:
“We need to adjust our losses somewhere. Most male employees are primary heads of household supporting
their families. This is temporary, and an alternative to laying all of you off. Please let it go…”
The audacity! He implicitly threatened that if we pursue our concerns, we will lose our jobs. Clearly women are
still viewed as inferior to men. Do we not have the same rights as men? Do we not support our homes and
families as well? We are equally affected by Covid-19, so why are we being discriminated against in this manner?
I expect that you will investigate these complaints on each level and take the appropriate, immediate action
against Mr. Silvester, as well as remedy the egregious discriminatory wage practices or I will be forced to contact
my attorney about the matter.
On behalf of your female staff,
18
CapraTek Employee Complaint Letters
Mona Sims
John Braganza
259 White Springs Dr.
Athens, GA 30601
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Benefits Discrimination Claim
Dear Ms. Martin,
I was hired by the company two years ago, to work at the warehouse as a porter for the Manufacturing Center. I
have a problem that I would like to make you aware of, and I am hopeful that you will be able to offer a solution.
As you are aware, we in the warehouse are considered essential employees. The warehouse is a place with a lot
of exposure, with so many employees working together, moving, sorting, and delivering computer components
and other products. At the time of hire, I was not offered health or life insurance. Recently I learned that most
employees are entitled to receive insurance as a benefit, with the exception of workers at the warehouse, who
are considered on the lower tier, and coincidentally also those employees with the lowest wages. I believe this is
discrimination, especially in light of the coronavirus outbreak when employees are forced to work and put their
lives at risk.
I was kept in the dark for two years. Now, I demand better compensation and health and life insurance.
Currently, the pandemic is taking a toll on everyone. There is a high rate of death and every day someone we
know is dying. I have a young daughter who I am responsible for. God forbid, if something happens to me, I want
to ensure security for my daughter.
Being a porter is a difficult job. I have always worked hard, and my supervisor has never complained about me. I
feel hurt now seeing how the company I was always so loyal to, never cared about me. I talked to my supervisor
about it and he is unwilling to support me.
A colleague of mine mentioned that he tried approaching management in the past but that required all
employees’ involvement, and they avoided such meetings with HR because it is a long and difficult process. They
feared if they made too much of an issue, they would face retaliation and even lost their jobs.
I am taking a bold step and risking my job writing to you, but the severity of the situation outweighs the risk of
doing nothing. I hope that you will address this matter as soon as possible, and I wish to remain anonymous.
Sincerely,
John Braganza
19
CapraTek Employee Complaint Letters
Geoffrey Jones
876 Pikes Place
Athens, GA 30301
United States
October 7, 2020
Ms. Renae Martin
HR Business Partner
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Protected Class Discrimination Claim
Dear Ms. Martin,
I have been employed with the Manufacturing Center for the past five years. I’ve worked my way up through the
ranks, and currently hold the position of Senior Distribution Manager at your Atlanta warehouse. Over the past
several months there has been talk around the plant of a push by management to move toward a younger
workforce, and to install more diversity in the workplace. IE: hire younger, people of color.
As a senior level employee, I was certain that if this were true, I would have been involved in the discussions. But
as of yet I have not been included in any conversations to that effect. That was, until today.
When I arrived at the office this morning, a high-ranking member of the human resource department was on
site, and I was called into an impromptu meeting. It was revealed to me that “due to the coronavirus outbreak,”
the company would be trimming its workforce to manage the bottom line. And lo and behold, my position was
being eliminated effective at the end of the current pay cycle.
I am a 52-year-old white male. In light of the recent chatter among the staff regarding the company’s wish to
eliminate older, “white” employees I can only surmise that this is related to the termination of my employment.
When I questioned the HR manager, they would only state that they did not have anything further to discuss,
than what was explained to me. But this is not a satisfactory answer and considering the circumstances I am
filing a grievance with the Human Resources department for wrongful termination based on my protected status
– being over 40 years of age. Not to mention my race, and how that may play a part of this.
Per the grievance procedure outlined in our handbook I will expect an answer no later than one week from
today. Accordingly, I will be speaking with the EEOC to determine my course of action.
Sincerely,
Geoffrey Jones
20
CapraTek Employee Complaint Letters
Adam Humphrey
905 Hillsboro Drive
Athens, GA 30302
United States
October 7, 2020
Ms. Renae Martin
HR Business Partner
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Working too many hours
Hi Ms. Martin,
As a high school sophomore, I was hired to work part time as a parts runner for the manufacturing
plant. When I was asked if I had restrictions to my schedule, and told the hiring manager that I would
only be able to work weekends, and one day during the week, he said it would be no problem.
Between sports and activities and my schoolwork I just can’t work more than that.
At first it was no problem, but over the last month I have been put on the schedule for 3 days a week,
and on weekends. Last week wasn’t that big of a deal because it was the first time, but now again this
week it’s the same thing. So, I complained to my manager Mr. Jones and told him I could not work that
many days. But he told me he had no choice, because due to the coronavirus they are short-handed,
and too many people are out sick.
I don’t want to lose my job, but 5 days a week is too much for me. I need to focus on my schoolwork,
which is the most important thing to me. Plus, my parents are mad and won’t allow me to continue to
work here if I have to work this much.
I like my job, and I want to work. So, if you could talk to my manager Mr. Jones, and please tell him
that I am just 16 years old, and a high school student, I would appreciate it. I can work on the
weekends, and one day a week, but not any more than that.
Thank you,
Adam Humphrey
21
CapraTek Employee Complaint Letters
Joanne Martin
1215 Greenbriar Way
Athens, GA 30302
United States
October 7, 2020
Ms. Renae Martin
HR Business Partner
The Manufacturing Center
3000 North Trail – Ste. 191
Atlanta, GA 30301
Ref: Schedule Accommodation for Single Mother
Hi Ms. Martin,
Thank you for reviewing my letter. I am writing to you today to ask for some help with my work
schedule. About a year ago I was hired to work at the distribution center and was given a schedule that
was supposed to be consistent. But over the past several weeks my schedule has changed on a regular
basis. Sometimes I am even called at the last minute to come in and cover shifts for other people.
In a perfect world this would be ok. But as a single mother who relies on a set schedule, and day-care
to watch my children when I am at work, I just can’t be expected to drop what I am doing and come in
every time someone calls out.
I understand that people are sick, especially now because of Covid-19 people are using it as an excuse
to call-out any time they have a headache, or just don’t feel well. But I was not hired to be on call. I
was hired to work a set schedule with the expectation that the company would work with me, as a
single mother.
When I complained to my manager, they told me that they need me to work, and that if I am unable to
come in when they need me, that they would write me up, and that three write-ups means I would be
fired.
Today I was written up for the first time. It is a horrible feeling, and I am afraid that I am going to lose
my job. This is just wrong. I depend on this job to support my family. I need your help to speak with my
manager. They are being unreasonable, and I just don’t think it’s right, what they are doing to me.
I appreciate anything you can do to help explain the situation.
Thank you,
Joanne Martin
22
CapraTek Employee Complaint Letters
Monica Fuentes
1215 Greenbriar Way
Athens, GA 30302
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Atlanta, GA 35031
Ref: Workplace Bullying and Harassment Claim
Hi Ms. Martin,
I am writing to you today for help with a workplace situation that has left me confused, and unable to
continue working.
I was hired to work at the manufacturing center in January of this year. Under normal circumstances
when the center is operating properly, there have been no problems. But since the pandemic has
started and some workers are able to work from home, like most of the management, we have had
limited oversight on shift.
With these changes, our normal shift manager is no longer working on our shift, and they have a new
person in charge. Since then, I have been having an issue with one of my co-workers. I am part of the
LGBTQ community, and one of the girls I work with is clearly homophobic. So, we have been having
some issues. Mostly verbal altercations, because we don’t see life the same, but now it is starting to
get out of hand, and I feel like I am being bullied.
Yesterday when I came to work, there was vulgar graffiti on my locker, and in the lunch room this
person made comments to me in front of other employees asking if I liked what she wrote on my
locker.
If that is not bad enough, this girl is dating the new supervisor. So, I have nobody I can turn to if I want
to make a complaint. My old manager used to watch out for me, but he is no longer around, so I am
writing to you.
Is there something you can do to stop this girl from harassing me at work? I feel like the situation is
getting out of control and I am beginning to fear for my safety. Please help me.
Thank you,
Monica Fuentes
23
CapraTek Employee Complaint Letters
EMERSON CARTER & ASSOCIATES
210 Jack Benny Parkway
Atlanta, GA 30301
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Atlanta, GA 35031
Ref: Wrongful Death of Ms. Susan Harewood
Dear Ms. Martin,
As I notified you on 20 September 2020, my clients Marshall and Sandra Harewood are seeking
damages in the wrongful death of their daughter Susan Harewood. Susan Harewood was a young 25year-old healthy female who contracted COVID-19 on the premises of The Manufacturing Center while
delivering parts as a UPS Driver. This young lady suffered through weeks of hospitalization, pain and
suffering before finally succumbing to her illness on September 15, 2020.
Our preliminary investigation shows that there was a COVID-19 cluster outbreak within your
organization that led to the death of Ms. Harewood. Another young woman, Samantha Lopez was one
(1) of several contractors working on your premises who also contracted the COVID-19 at the
Manufacturing Center.
It is our position that your company was grossly negligent, as management knew well in advance that
several employees and contractors were exhibiting symptoms prior to Ms. Harewood’s death. Your
company willfully allowed employees to come to work, spreading the disease. Your negligence allowed
Ms. Harewood to die through a failure to act, and breach of a duty to care.
We are also aware that the company hired new employees and failed to confirm or check to see
whether they exhibited any signs of the virus. The Manufacturing Centre willfully allowed persons who
exhibited signs of the virus to remain working and did not provide any personal protective equipment
(PPE) to Ms. Harewood or other members of staff.
The Manufacturing Center failed to implement an infectious disease preparedness and response plan
to limit infection. Your company failed to follow CDC regulations and guidelines to prevent COVID-19
infection on your premises. The company also failed to enforce social distancing guidelines. All
contributing factors to the demise of my client.
Ms. Harewood’s parents are requesting a settlement amount of six million dollars ($6,000 000.00). At
the time of her death, Susan Harewood was a healthy, 25-year-old woman who enjoyed an extremely
close and loving relationship with her parents. She had only begun living, and had plans to complete
her education, start a business, marry, and start her own family.
24
CapraTek Employee Complaint Letters
The tragic nature of this case is compounded by the fact that the Harewood’s lost another child to
COVID in March of this year. Her sister who was studying in China when the initial outbreak occurred
and whose body the family was not able to obtain. Susan’s father Marshall suffered a massive stroke
immediately after learning of Susan’s death. Marshall is now permanently disabled. Susan was the
breadwinner of the household and would have contributed significantly to her father’s support for the
remainder of his life. Mr. & Mrs. Harewood have now been deprived of financial support as well as the
love, care, comfort, and affection, that their daughter would have given to them had she still been alive
today.
This offer to settle will remain open for 30 days from the date of this letter. If it has not been accepted
by that time, this demand will be withdrawn, and we will proceed to court.
Thank you for your cooperation.
Yours Truly,
Emerson Carter
25
CapraTek Employee Complaint Letters
WINN & EXIT LAW FIRM
710 Alabama Ave. Suite 211
Atlanta, GA. 30301
United States
October 7, 2020
Ms. Renae Martin
Director, Human Resources
The Manufacturing Center
1243 Lenox Rd. – Ste. 150
Atlanta, GA. 35031
Ref: Wrongful Death of Mr. James Clarke, Sr.
Dear Ms. Martin,
My client Leah Clarke is seeking damages in the wrongful death of her husband, the deceased, James Clarke, Sr.
Mr. Clarke was employed by your company, where he worked as a Customer Service Representative in the head
office prior to his untimely death on September 18, 2020.
We allege that Mr. Clarke contracted COVID-19 while working in your facility, The Manufacturing Center. We
further allege that the Manufacturing Center failed to provide a safe workplace or follow the recommended
health & safety guidelines that were to be enacted, in order to prevent such an egregious event from occurring.
Due to the company’s failure to mitigate this risk, there was an outbreak and workplace cluster which occurred
at The Manufacturing Centre. Even in light of this outbreak, the company neglected to shut the business down,
against local health officials’ recommendations. It is contended that Mr. Clarke contracted the coronavirus at
work because The Manufacturing Centre did not provide personal protective equipment (PPE) or implement a
number of other safety measures to protect against the spread of COVID-19. Safety measures such social
distancing, screening workers for the virus, and following state guidelines. It was through this negligence that
the death of Mr. Clarke was allowed to occur.
James Clarke was Leah Clarke’s husband and the sole provider of the home. Leah Clarke remembers her
husband as her soul mate, best friend, confidant, and caretaker. Mrs. Clarke has had to undergo counselling
since her husband’s passing as she is unable to cope with his untimely, and preventable death.
Mrs. Clarke has requested the following compensation highlighted in the table below:
EXPENSES
COSTS
Funeral Home Expense
$7,500.00
Hospital Bills
$52,850.00
Pain and Suffering of the Deceased
$1,000,000.00
Pain and Suffering of the Beneficiary
$1,500,000.00
Counselling Support
$15,000.00
26
CapraTek Employee Complaint Letters
Demand for Settlement
Given the clear negligence of your company, resulting in the wrongful death of Mr. James Clarke, Sr.
the beneficiary is willing to settle this claim for $2,575,350.00.
We appreciate your timely response. If we do not hear from you within 30 days of the date of this letter,
we will proceed with the filing of a wrongful death suit.
Sincerely,
Winsome Meyers
Win & Exalt Law Firm
27
CapraTek Employee Complaint Letters
Charles Jackson
609 South City Way
Skokie, IL.
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Workplace Discrimination Claim
Dear Mr. Webb,
I am writing you this letter to highlight my concern about the discrimination that I
am facing in my workplace. I have been a disabled employee of the firm for quite
some time now, working as a data entry clerk, managing the data in the logistics
department.
With the outbreak of COVID-19, our company had to reduce its expenses and
strategize for the financial losses that are expected to be incurred. Because I am
physically disabled, I cannot perform a given task as quickly as my colleague. But I
believe that the company has a responsibility to reasonably accommodate me and
has done so until now. Two days back, my department manager, referring to the
WARN Act, informed me about my layoff and gave me just one months’ notice,
instead of two to search for a new job. He said the company needs a more efficient
workforce to deliver the tasks and duties quickly and accurately with a limited
number of employees because of COVID-19.
I do not understand how this can happen. It is not logical to terminate a long
standing, disabled employee. Is it my fault if I am disabled? I accept I am not as fast
as anyone else but that is the best I can do. I believe that it is my right to remain on
the job and be paid equally, without the threat of discrimination. The manager is
not at all cooperative and himself provided a list of employees to the HR
department that he sees as unfit for the job. Also, there is a notice that employees
are to be given 60 days before a layoff occurs. Even if I were to accept this decision,
the period itself is unjust.
Not only do I believe this to be discriminatory, but an attack on my abilities to
perform the job with a reasonable accommodation. In this time of Covid-19, when
businesses are shutting down and no one can find a job, let alone a disabled
candidate, I cannot imagine losing this job on which I so depend to survive.
28
CapraTek Employee Complaint Letters
I ask you to take immediate action and prevent this discrimination. I am looking
forward to your cooperativeness, otherwise I will have no other option but to
contact the EEOC and file a wrongful termination and discrimination complaint.
Yours sincerely,
Charles Jackson
Amare Kwame
851 Pearl Gate
Chicago, IL 60603
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Workplace Racial Discrimination Claim
Dear Mr. Webb,
The purpose of this letter is to bring to your notice the racist situation at our office. I work here as one of the
back-end engineers. With the onset of Coronavirus, most companies ordered employees to work from their
homes and so did our company. With no vaccine available and the only prevention method being to isolate
oneself, this was considered as the best decision by all the employees, including me.
Only limited “essential” employees with important work were to attend the office to avoid human contact.
Things were going fine until I discovered that nearly all the people of color (African American, Latino, etc.) in the
workforce were called back to work at the office, as “essential employees.” Yet a colleague who is equally
qualified to perform the same tasks was not called to the office, and he is Caucasian.
Minorities are already discriminated against on daily basis. And now seeing that we are discriminated against,
even in such crucial times, is unexpected. If you wish to minimize my complaint by stating that it is just a
coincidence, then don’t. Please do not insult my intelligence. At the workplace, the only people you will see
working are people of color. There is rarely a single white employee to be seen, even if it is extremely important
for such employees to be at the workplace.
Three days ago, there was a particularly important document that needed an urgent signature from the Chief
Engineer. Upon calling, he demanded the document be sent to his residence for the signature. It would’ve taken
longer to send & receive the papers than had he been on-site. Upon insisting they be mailed, he blurted out that
he is “strictly prohibited from coming to the office because we are told white lives matter.”
If it weren’t for his brazen statement, I wouldn’t have realized the reason behind no white employee attending
the office. It is extremely shameful, demeaning, and incomprehensible to see this. We have our families to go
29
CapraTek Employee Complaint Letters
home to, we risk our lives daily and yet are directly discriminated against on daily basis. This was yet another
painful reminder of the injustice we face in every-day life.
I am going to the union if my letter isn’t responded to. I want to know why only the minorities in the company
were asked to attend the office while the company policy clearly states no discrimination will be accepted. You
should know that all lives matter!
Yours sincerely,
Amare Kwame
30
CapraTek Employee Complaint Letters
Arya Arista
192 Mountain Valley Rd.
Peoria, IL 61603
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Workplace Hostile Environment Claim
Dear Mr. Webb,
I am writing about a hostile work environment I am facing in the office, based on my nationality and since I
made a complaint about a lack of concern for our health & safety. I am from Bangladesh, working for the
company as a computer operator. My job has been deemed as essential, as office based as I need to track data
and activities and document things on a daily basis.
It is a co-working space here as you already know, without any consideration of social distancing. I have a preexisting condition of asthma and because of the high number of Covid-19 cases, I believe my health & safety to
be at risk. If by any chance I catch the virus I am likely to be severely impacted, and perhaps die.
In my office at The Manufacturing Center, no one is following proper SOP’s and management is negligent in
enforcing any of the recommended guidelines. As long as the work is not compromised, and the deadlines are
met everyone is allowed to do as they please.
Many of the employees working here have family or friends that have tested positive for the corona virus and
are risking other’s lives by coming to the office. Management isn’t prepared to provide masks or PPE, no
sanitization procedures or social distancing arrangements have been implemented, and we all at risk of catching
the virus.
This week a corona recovered employee was allowed to re-join the workforce, apparently based on an antibody
test result which is highly unreliable. He told me he was not asked to submit a medical certification report
clearing him to return to work. This is highly irresponsible!
When I expressed my concerns, my manager said, “You are over-reacting. It is better to work here than to go
back to your country, so work if you want to, or leave. We have many applications, so I can easily replace you.”
Just because I am from another country doesn’t justify these derogatory comments. I am an employee with
equal rights and being from Bangladesh does not make me any less of a person.
I want you to take my complaint seriously and investigate these violations. Aside from being discriminated
against because of my country of origin, I am subject to a hostile workplace with no regard for employee’s
health and safety. I do not want to spend time in a hospital. Please act before it is too late.
Yours sincerely,
Arya Arista
31
CapraTek Employee Complaint Letters
Jennifer Stills
468 Maxim Hall
Galena, IL 61036
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Request for Maternity Accommodation Claim
Dear Mr. Webb,
As you know, I have worked with the company as one of your computer manufacturing instructors for more
than two years. Until now, I have had no issues with my employment, but unfortunately things have recently
changed.
The current situation is, I am now an expectant mother and have requested an accommodation to my schedule.
As you’re aware, because of Covid-19, all “normal” activities and functions are shifting to online platforms,
which has led to a greater demand for computers and related supplies which has created a burden on our
instructors. Because I am considered an essential employee and losing an instructor at this critical time would
leave the company short, my request for accommodation has been denied.
As a computer manufacturing instructor in this company, I am tasked with training employees. Unfortunately,
the pandemic has created an additional burden, on top of my regular responsibilities. I have accordingly
extended my work hours and taken on an additional workload but cannot continue to work at this pace. I am
now suffering from stress related complications, as the appropriate amount of rest, and work-life balance have
become extremely difficult for me, if not impossible. Not to mention the demands to remain at the office for
lengthier hours have exposed myself and my un-born child to a much greater risk of contracting the coronavirus.
I’ve been doing this job a long time. Long enough to know that this is a role that I can accomplish from home,
with limited hours at the workplace. I do not believe that I am being unreasonable, and am willing to split time
on site, and remotely to achieve our goals. I have spoken to my manager regarding my condition and asked that
she consider the options, including approving maternity leave, but she is reluctant, and to date has not
approved either of my requests. She expressed that under the circumstances, all employees are over-burdened,
and no one can assume my workload right now.
I understand that, and I am a fully committed employee, but my current condition requires accommodation. I
respectfully ask that you to consider the situation and approve my request for accommodation, and/or
maternity leave.
Yours sincerely,
Jennifer Stills
32
CapraTek Employee Complaint Letters
Hector Francis
Galena, IL 61036
United States
October 7, 2020
Mr. Terry Webb
Hiring Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Immediate Action Required to Implement Covid-19 Protocols
Good day, Mr. Webb,
I am an employee at the Manufacturing Center, and work as a logistics coordinator in the shipping
department. I have been chosen to represent of a group of your employees. We are all essential,
frontline workers, and have a great concern about the ongoing pandemic that has spread within our
workplace. It is no secret that our company has lost several members to the illness, and a great
number of our co-workers are at risk of being next. It is our expectation that you address the below
grievances in an immediate and efficient manner.
We demand the company take action to address the following issues:
•
•
•
•
•
A failure to follow current CDC guidelines for a safe workplace
A failure to provide proper Social Distancing protocol
A lack of company issued Personal Protection Equipment (PPE)
Shortage of sanitation staff to maintain clean facilities
Favoritism of some workers who are allowed to work from home
We would like to know how quickly you can take action and create a safe workplace for all of our
workers. We would also like someone to speak to us about who is considered essential, and who is
allowed to work from home, and why? It doesn’t seem right that many of our managers are allowed to
work from home, while we toil here at the warehouse and risk our lives every day. We just want to be
treated properly, and for someone to speak with us about our questions.
Thank you for your time. We are looking forward to meeting with you and finding a solution to these
problems.
Respectfully,
Hector Francis
33
CapraTek Employee Complaint Letters
Mark Wilson
775 Texas Port Drive
Galena, IL 61036
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Violation of Civil Rights
Dear Mr. Webb,
For the past two years I have been a full-time employee on the administrative team, here at the Park
Ridge facility. I love my position and have made lifelong friends who are more like family.
As a full-time employee I am provided a number of benefits, not the least of which is health insurance,
including medical, dental, vision, and other helpful perks such as disability, life insurance, pet
insurance, etc.
Recently I was married to the love of my life. In light of the terrible pandemic, we have decided that we
would like to update my health insurance to cover my partner. To my dismay, I was informed this
morning by our human resources department that our insurance coverage does not recognize gay
marriage. I’m really not sure what to say to this? I am shocked. I am hurt. I am offended and I am
angry!
As a gay man, I am abhorred to learn that our company does not value the life of my partner to the
extent that they would provide us spousal coverage, on the premise that he is gay. Do you not
recognize him as a human being? I just do not understand in this day and age, how we happily provide
health insurance to married couples, as long as they are not gay couples? I’m sorry, but I cannot get
past this outrage.
I write to you today to ask for answers. Whom may I contact to discuss how these decisions are made
within our company? I have already placed a call to my congressman, and plan to contact a civil rights
attorney. But I demand to speak with someone in our company who can look me in the eye and tell me
that we are not due the same rights and privileges as “straight” couples.
I await your call.
Respectfully,
Mark Wilson
34
CapraTek Employee Complaint Letters
Omari Masri
145 New Park Circle
Peoria, IL 61035
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Violation of Protected Class – National Origin
Dear Mr. Webb,
Thank you for reviewing my letter.
I was recently hired as an unpaid Intern at the Park Ridge office for the Manufacturing Center. As a
junior at the University of Illinois, I study Logistics and Commerce and I was happy to be given this
opportunity.
Upon my hiring, it was explained to me that my role would entail working with our logistics team and
managing data for the shipping & receiving office. About one month into my internship our office was
hit with an outbreak of the coronavirus. Several of our staff have become ill and are out of work
indefinitely. Because of this, the remaining team are expected to pick up additional work to make up
the slack. Understandable for most employees. However, as an intern I am not paid a wage. I do not
believe that I should be expected to cover the responsibilities for others who are compensated for such
time. But now I am forced to work the shifts of two sometimes three others, for no wages. I could
understand if I was being paid, and that this was a full-time job for me, but I cannot continue with such
a schedule and remain focused on my studies.
When I spoke with my supervisor at the Logistics office his explanation was that “this is how it is in the
real world. I don’t know how it’s done where you come from, but you could always go back there if
you’re not happy here.” I am originally from Nigeria, and am in the U.S. on a work visa.
I think this was completely uncalled for. To attack my nationality for a simple question about my
schedule? I am very hurt by this, and not sure that I should return to the office with this person.
I was told by a co-worker to contact you for guidance, because you are very helpful. So, I would
appreciate it if you could help me to settle this matter, and to find a solution that will be acceptable to
my University, so that I may complete my internship in good standings, and to address the attack against
my nation of origin.
Please help.
Yours truly,
Omari Masri
35
CapraTek Employee Complaint Letters
Jessica Ko
145 New Park Circle
Peoria, IL 61035
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Hostile Workplace – Retaliation
Dear Mr. Webb,
I would like to take a moment to explain a situation that has been ongoing at our office. I work in the
Tech department at our Park Ridge office. I’ve been employee for just about one year now, and so far,
have enjoyed my job, and my co-workers.
But recently due to the guidelines put in place for managing Covid-19 and the safety protocols that we
must follow, there has been some tension rising among the staff.
Under these new guidelines, one of my responsibilities as part of the IT team is to oversee the contact
tracing for all of our employees. It’s no secret that any time someone gets ill, or reports symptoms,
that they have to complete a lengthy questionnaire in order for us to efficiently track who they have
been in contact with, or may have been exposed to.
Well clearly some of our employees feel this is a violation of their right to privacy, and have taken it out
on me, personally, as well as others in my office. It is pretty much useless to try to explain how it
works, and that their privacy is protected. Most don’t want to hear anything about it, and just assume
that we are sharing their information with any number of governmental agencies, internal offices, etc.
Recently I made a complaint about one such employee, who was verbally abusive to me, and to
another co-worker. Apparently, it got out that I had filed a complaint to management about this
individual, and now they are threatening me with physical violence. This is uncomfortable for me. I
take their threats seriously and now fear for my safety whenever I am at work, coming or going from
the office, or even when I am home, or in town. It’s a small town, and as an Asian woman, I don’t
exactly blend in.
My manager gave this person a warning, but nothing else was done. They are still allowed in the office.
I still have to see them on a daily basis. I don’t know what can be done, but surely there must be some
protections? So, I am writing to you for some help. Can you please help me understand my rights and
tell me what can be done to A) provide for my safety, and B) discipline or terminate this employee for
their aggressive and threatening behavior.
Thank you for your help.
Sincerely,
36
CapraTek Employee Complaint Letters
Jessica Ko
37
CapraTek Employee Complaint Letters
Benson Hedges
145 New Park Circle
Peoria, IL 61035
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Unsafe Workplace
Dear Mr. Webb,
I believe it is my responsibility to inform the company about a life and death situation taking place at
our main facility, the Manufacturing Center. That may sound exaggerated, but I assure you, it is not.
In just the last three to four weeks, a large number of our staff has tested positive for the Coronavirus.
There are so many employees out of work, that it is nearly impossible for us to function properly, not
to mention act as though nothing is wrong. Not even to mention that the senior staff has been
approved to work from home, while the newer staff are required to be at the office. Now those of us
that are here live in fear that we will be next.
Something must be done. The office is in total disarray. Our local management clearly does not have a
grip on the situation, and every day someone else goes out on sick leave. I think we have lost at least
two dozen employees to illness, so far. Thankfully, no one has died yet, that we know of.
I beg that you please send someone from the main office to view the situation and provide some sense
of leadership and direction. Those of us that are still here need to work to survive and are essentially
held hostage to our pay checks. Please understand, we risk our lives every day just by coming to the
office.
Our lives literally depend on you.
With the greatest of hope!
Benson Hedges
38
CapraTek Employee Complaint Letters
Seals & Crofts
Attorneys at Law
2 Diamond Lane
Chicago, IL 60632
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Wrongful Death Claim – Richard Howell
Date of Incident: September 15, 2020
Dear Mr. Webb,
Please be advised that our office has been retained to represent the family of Richard Howell, in regard
to his wrongful death as a result of contracting the coronavirus while working as an employee at your
Manufacturing Center facility. We ask that all future correspondence or oral communication be
directed to our office and that there be no direct contact with our clients in this matter.
Please forward a certified copy of all company health & safety protocols, workplace policies and Covid19 mitigation plans, trainings and procedures, with the following information within the next fifteen
(15) days with regard to each known policy of insurance, which may provide liability insurance for this
claim:
1. Name of the insurer(s);
2. Name of each insured;
3. Copy of limits of liability coverage:
1. for personal injury, including death;
2. property damage; and
3. medical expenses
When we complete our full investigation we will send to you, or the appropriate representative from
your insurance company, a settlement proposal in an effort to expeditiously resolve this claim in a
manner that is fair to all parties and saves all concerned parties time and future legal expenses.
We look forward to working with you and your counsel toward a prompt and amicable resolution of
this matter. If you have any questions or concerns, please feel free to contact me.
Sincerely,
Evander Seals
Seals & Crofts – Attorneys At Law
39
CapraTek Employee Complaint Letters
Morgan & Morgan
Attorneys at Law
18 West End
Peoria, IL61611
United States
October 7, 2020
Mr. Terry Webb
General Manager
The Manufacturing Center
3600 Peachtree – Ste. 200
Park Ridge, IL. 60016
Ref: Wrongful Death Demand – Boris Senty
Date of Incident: September 10, 2020
Dear Mr. Webb,
You are hereby provided notice that the family of Boris Senty, known herein as Clients have filed a claim of
wrongful death against the Illinois Manufacturing Center. This letter serves to clarify our position that the
Company was negligent in its responsibilities to provide a safe and healthy workplace for its employees, by
failing to maintain proper measures to limit the risk and spread of the novel coronavirus within its premises, and
amongst its employees.
Mr. Boris Senty was employed by the company, as a logistics engineer up to the date of his untimely, and
preventable death, on September 10, 2020. He was a faithful and dedicated employee of the company for over
ten years. Mr. Senty was also the sole provider for his family.
Our clients remember Mr. Senty as a gentle, and loving man, a father and husband who spent all of his free time
with his children. The loss of Mr. Senty will be difficult for the family to endure. The emotional damages of many
months and years ahead, the holidays and special moments that have been taken from them cannot be
imagined or understated.
Therefore, our clients seek damages in the amount of $2,500,000. Damages include; medical expenses in the
amount of $35,000; funeral expenses in the amount of $5,000, lost wages in the amount of $1,050,000 and
personal injury in the amount of $1,000,000.
We wish to settle this claim amicably, and not involve the courts, which will surely find in favour of our clients.
Negligence on the part of the company is clear, and undeniable.
If we do not hear from your representatives within fifteen (15) business days of the date of this letter, we will
pursue legal action and a full trial.
Sincerely,
George Morgan
40
CapraTek Employee Complaint Letters
Morgan & Morgan – Attorneys at Law
41
