disability discrimination and retaliation settlements

The employee charged that he was fired because he filed a workers compensation claim and requested accommodation for his disability, a violation of the ADA. Available 24/7 Immediate Response Experienced Lawyers . Despite the employer's evidence of a legitimate reason for the termination, the retaliation claim suffered from the same weaknesses as the discrimination claim. $250,000 Disability Discrimination Settlement. The investigation, which ended in mid-December, revealed many violations of the break policy by employees on both night-shift crews. As to the plaintiff's FMLA claim, the court found similarly that the plaintiff had presented enough evidence to raise a presumption of unlawful retaliation, notably that the employer terminated the plaintiff just over two months after his return from a four-month FMLA leave and had not made the doctor-recommended accommodations for the plaintiff's disability. A. Plaintiff's Disability Claims Are Without Merit. 2004) (discussing prima facie case in ADA hostile work environment claims). The case had gone to trial and is pending. Please enable scripts and reload this page. DoNotPay can help you prepare for your driving test or schedule a DMV appointment without sweat! It also applies to employment agencies and to labor organizations. $1.675 million (age discrimination) $1.5 million (negligence) $1.3 million (whistleblower retaliation) $1.265 million (disability discrimination) $1 million (breach of contract) $950,000 (sexual harassment) $865,000 (wrongful termination) You cannot claim punitive damages for cases of: The size and liquidity of the employer have a direct impact on their ability to pay compensation. document.head.append(temp_style); You may be trying to access this site from a secured browser on the server. Walmart declined to remedy Spaeths schedule, and she began experiencing attendance problems. Law360 (February 27, 2023, 7:09 PM EST) -- A lawyer that New York plaintiffs firm Napoli Shkolnik PLLC sued last week for allegedly bucking her employment contract by "quiet quitting" fired back . Finally, she was concerned that the "but-for" standard in employment discrimination cases cannot address the mind-related characteristics that constitute motive. Still, the large award of punitive damages indicates that the jury considered Wal-Marts discriminatory conduct beyond the pale. Share sensitive information only on official, secure websites. Please log in as a SHRM member. An official website of the United States government. Neither members nor non-members may reproduce such samples in any other way (e.g., to republish in a book or use for a commercial purpose) without SHRMs permission. Find the latest news and members-only resources that can help employers navigate in an uncertain economy. 5. Click to browse through wrongful discharge lawsuits from PA free. Reasonable accommodation may include, but is not limited to: An employer is required to make a reasonable accommodation to the known disability of a qualified applicant or employee if it would not impose an "undue hardship" on the operation of the employer's business. In 2012, for example, 38 percent of EEOC charges were retaliation cases. Former Teacher's Disability Discrimination, FMLA Retaliation Claims Get Green Light for Trial. Your Question AnsweredCan Businesses Discriminate Against You? App. A federal jury recently delivered a eye-popping $125,150,000 verdict in a disability discrimination case against Walmart. Although the punitive damages amount will likely be reduced because of the statutory cap, the verdict in this case indicates that juries intend to punish employers who break the law by discriminating against disabled individuals. The plaintiff was able to file a lawsuit against this company with the help of the EEOC and was given a $186,295 settlement amount. From fighting discrimination to solving travel woesthats how diverse DoNotPays portfolio is! The company allegedly also engaged in retaliation against employees who complained. A previous DynMcDermott Petroleum employee re-applied for a position with the same company as a planner/scheduler and was denied due to his age and the fact that his wife was cancer-stricken. Do you prefer road trips? This information is not intended to create, and receipt or viewing does not constitute, an attorney-client relationship. Hinson v. U.S.D. This may include facility modifications, schedule adjustments, or equipment, see id., and can even include transferring an employee to a new position for which they are qualified. Although you are expected to . If you or a loved one would like to know more about high disability discrimination settlement amounts, or you have a case yourself, get your free consultation with one of our Disability Discrimination Attorneys! Code, 12900 - 12996 .) The case was settled for $160,000. The FY 2020 data show that retaliation remained the most frequently cited claim in charges filed with the agencyaccounting for a staggering 55.8 percent of all charges filedfollowed by disability, race and sex. Free Consultation (888) 694-7132. . The application was denied employment as an instructor because she has partial paralysis in her left hand. The stated reason was the plaintiff's poor performancespecifically, that he had known about the break-policy abuses and had done nothing about it. These were whether the employers refusal to permit working from home was an adverse action and whether the resignation constructive discharge. I am a litigator helping professionals navigate employment challenges. On that basis, a jury could reasonably reject the employer's claim that the plaintiff's poor performance was the true reason for termination. The Equal Employment Opportunity Commission (EEOC) defines retaliation as an adverse action against a covered individual because he or she engaged in a protected activity. He was denied the right to take time off to seek psychiatric help for his depression. Here are four reasons you should consider Bononi Law Group. McGuinness v. Silgan Containers, D. N.J., No. var currentUrl = window.location.href.toLowerCase(); TVII Retaliation Age Disability EPA . Our app wont do much when youre drinking cocktails at a beach, but it will do wonders if you run into problems. Michael J. Borrelli handled the matter for the Firm. A federal jury recently delivered a eye-popping $125,150,000 verdict in a disability discrimination case against Walmart. Settlements and Determinations; Settlements. This individual has previously suffered burns, both losing his hands as well as disfiguring his face, and was denied employment because of his burns. No. Is my attorney incompetent? The EEOC will contact you to talk through your next steps. In Spaeths case, her condition substantially limited a major life activity, entitling her to protection under the Act. The ADA covers employers with 15 or more employees, including state and local governments. 2 See Hendrix v. Pactiv LLC, 488 F.Supp.3d 43, 51 (W.D.N.Y. In calculating future losses, this could be affected by how seriously you have attempted to find alternative employment, Your legal and court fees must be deducted from any compensation amounts to arrive at your actual payout sum. Suite 200. Examples of Legal Actions Charging Retaliation. If you are unsure about needing a second opinion, you should reflect on your experience with your current attorney. Highly recommend! Proving Damages in Wrongful Termination Claims. Spaeth filed a complaint with the Equal Employment Opportunity Commission (EEOC), who brought a lawsuit against Walmart in the US District Court for the Eastern District of Wisconsin. Because employment discrimination continues to be prominent, many victims contact our law firm with questions about one of the major forms of employment discriminationdisability discrimination. Workplace discrimination is illegal for a reason. } 1:17-cv-00070 (E.D. The average discrimination settlement amount you can expect is around $40,000. This individual claimed disability discrimination and was eventually settled with $750,000 after trial. Civil Rights Violation, Disability Discrimination, Government Negligence, Retaliation, Constructive Discharge, Labor . She then resigned after being told that her job was full time and that she needed to commit to it. After her termination, Spaeth and two of her family members met with her employer to request that she be reinstated. She alleged that the USPS has subjected her to disability discrimination and harassment. For instance, the national average payout for religious discrimination claims is around $40,000 to $50,000. You will also find a few examples of past disability discrimination settlements and verdicts to help you understand how different cases are valued. Our law firm is strictly based on contingency, so our clients will not have to pay anything until our expert disability discrimination lawyers win their casedo not hesitate to call our law firm to schedule a free consultation or free second opinion with our skilled lawyers. He was promised job security and was told to focus on recovery. You may opt-out by. California Employment Attorneys Group understands the distress and hardship that accompanies being the victim of disability discrimination. Employers should take disability discrimination seriously, and this substantial jury verdict illustrates why. However, in or around November 2014, Walmart instituted a computerized scheduling system which changed the hours which Spaeth was required to work. Wis., No. Bringing forth viable and strong claims of retaliation will promote change because it will force schools to assess their behavior, return to parents and students the power to assert their rights, and inform and educate the courts and public that disability-based discrimination in public schools is a continuing problem. A production supervisor with a disability could pursue his claims for discriminatory and retaliatory termination because there were disputed issues of fact that should be heard by a jury, the U.S. District Court for the District of New Jersey decided. The United States Supreme Court has decided many cases that deal . Later in 2017, due to serious and chronic kidney disease, the plaintiff twice took leave under the FMLA. Well done and Thank you! The U.S. Virtual & Washington, DC | February 26-28, 2023. An employee seeking a discrimination settlement might be discouraged by the seemingly low potential of financial compensation when filing a lawsuit against their employer. This amount will almost certainly be reduced to $300,000, as the ADA places a cap of $300,000 on non-economic damages, such as compensatory and punitive damages. Settlement of Personnel Actions Should Include Consideration of the Total Cost to the Government. Walmart had accommodated her scheduling needs for more than a decade, and had the available hours and employees necessary to keep Spaeth on her previous schedule. Time will tell. No problem! The cases that achieve million-dollar settlements and reach the media typically require vast amounts of time, which increases their cost massively. Members may download one copy of our sample forms and templates for your personal use within your organization. I couldnt have asked for more. On its motion for summary judgment on the disability-discrimination and retaliation claims, the employer had to show that there was no genuine issue as to any material fact, such that it was entitled to judgment as a matter of lawthat is, without the need for a trial. Our lawyers have the expertise necessary to tell you how much you can expect to receive as compensation. The plaintiff was able to file a lawsuit against this company with the help of the EEOC and was given a . TrueBlue and PeopleReady to Pay $125,000 to Settle EEOC Disability Discrimination and Retaliation Suit U.S. However, a reasonable accommodation must keep all of the essential functions of the job intact. These are a stand up group of Employment lawyers. is illegal for a reason. (New York), Rosenthal v. NY State Board of Law Examiners (New York), Rosslyn North Limited Partnership (New York), Saginaw County Sheriff Department (Michigan), Saginaw Township Police Department (Michigan), Sardi's Enterprises Restaurant (New York), Saxton Pierce Restaurant Corp (Mississippi), Schloer Enterprises (Bekins Van Lines) (Pennsylvania), Shelby County Court of General Sessions (Tennessee), Shopper's Landing Limited Partnership (Maine), Sixth Judicial Circuit of Florida (Florida), South Orange Village Township (New Jersey), Sprinfield City Utilities Mani Office(Missouri), Springfield-Greene Count Library district (Missouri), Szarlan, Arpin, Doe & Roe v. Conn Bar Exam (Connecticut), Taylor Home of Charlotte (North Carolina), Thousand Oaks Civic Arts Plaza (California), Trustees of Boston University (Massachusetts), Two Beacons, L.L.C., as Owner of Kentucky Fried Chicken Restaurant (Tennessee), Union Station 9 Theaters (Washington, DC), United Artists Theatre Circuit (Maryland), West Michigan ENT & hearing Center (Michigan), Wynock, Marie & Richard (Ocean Plaza Motel) (South Carolina), Yuma Elementary School District No. A blind individual applied as a night warehouse loader after his company eliminated his previous position as a drivers aide. The more complicated your case, the higher these fees will be. 2. Please purchase a SHRM membership before saving bookmarks. If you do, we'll connect you to a qualified lawyer today. Each case is different and dependent on many factors that influence the amount you may receive in a settlement. She was disciplined twice for attendance and punctuality concerns before being terminated in July of 2015. $("span.current-site").html("SHRM China "); Names confidential as condition of settlement. The applicant filed a disability lawsuit with the EEOC under the Americans with Disability Act (ADA) and Age Discrimination in Employment Act (ADEA). 1 Dept., May 04, 2021), the court held that plaintiff presented enough evidence to defeat defendants' motion for summary judgment on plaintiff's claims of discriminatory termination, failure to accommodate, hostile work environment, and retaliation.. As to plaintiff's wrongful termination claim, the court held that . The case went to trial this summer, and the jury returned a verdict last week. A .gov website belongs to an official government organization in the United States. This field is for validation purposes and should be left unchanged. An individual with a disability is a person who: A qualified employee or applicant with a disability is an individual who, with or without reasonable accommodation, can perform the essential functions of the job in question. In EEOC v. Wal-Mart Stores East, Spaeth showed she was a qualified individual under the Act. She had worked at Walmart since 1999 and had performed her job without incident until 2014. Following his termination, the plaintiff filed suit against Lewis Brisbois' client, alleging claims of disability discrimination, failure to accommodate, and retaliation. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. Retaliation in the workplace may be defined as a form of unlawful discrimination that occurs when an employer, employment agency or labor organization takes an adverse action against an employee, applicant or other covered individual because he or she engaged in a protected activity, including filing a charge of . An employee must establish the threshold elements of a claim to raise a presumption of unlawful discrimination or retaliation. A settlement is a formal agreement to resolve a complaint. Following a meeting in January 2018 to discuss break-policy violations, the company terminated both C crew supervisors, but only one of the D crew supervisorsthe plaintiff. . Title VII of the Civil Rights Act of 1964 prohibits employers from retaliating against an employee who has filed a charge with the EEOC.As part of their initial burden of making . The case, EEOC v. Wal-Mart Stores East, E.D. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. The comments about committing to the job could be a verbal warning by the employer and the denial of leave or work from home privileges could be an effort to prevent the employee or other employees from seeking accommodation or reporting discrimination. The case is pending. During those years, she had worked a regular schedule of 12:00 to 4:00 pm on three or four afternoons per week. Whenever you need to draft, fax, or mail legal paperwork, you can open our platform and use our fast and reliable tools for that. 4) An Illinois woman who had taken intermittent medical leave for 10 years because of breast cancer and other conditions and who received positive feedback on her job performance was fired when she didnt show up to work. In support of these claims, the plaintiff emphasized that surprising him with a drug test after he accepted the position with the company and resigned from his former . If you have been the victim of disability discrimination, you must take action. & Gas Corp., 195 F.Supp.2d 429, 436 (W.D.N.Y. For instance, a disability discrimination case under the Americans with Disabilities Act may allow for punitive damages (damages to punish . Such accommodation is intended to allow employees to do their jobs when it would otherwise be difficult for them to remain in their positions. Determinations Are you considering suing your manager or colleague in small claims court? $('.container-footer').first().hide(); Official websites use .gov DoNotPay can help you, How To Fight LGBTQ Discrimination in the Workplace, Life Begins at 40 if You Challenge Age Discrimination in Your Workplace, How to Report Racial Discrimination In the Workplace Anonymously, Fight Gender Discrimination With DoNotPay's Help, Fight Workplace Discrimination With DoNotPay's Help, What Is Mental Health Discrimination and How to Deal with It, How to Report Discrimination Against Women In the Workplace, A Company Can Be Sued for Discrimination if It Commits These Acts, How to Report Transgender Discrimination In the Workplace to the EEOC, Demystifying Title VII Gender Discrimination, Missouri Discrimination Law Explained in Full. Among the Commission's 2020 Settlements, fashion retailer Zara agreed to pay $30,000 in emotional distress damages and work to create employment opportunities for transgender, gender non-conforming, and non-binary New Yorkers ().The Commission has the authority to assess fines and obtain monetary damages for those aggrieved by violations of the New York City Human . An employer generally does not have to provide a reasonable accommodation unless an individual with a disability has asked for one. If discrimination turns into a hate crime, we can help you file for, legal paperwork, you can open our platform and use our fast and reliable tools for that. Your employer may offer to settle with you at any point within the process. No problem! I am so grateful to have found the California Labor Law Employment Attorneys Group. 12102. In the case of punitive damages, the amounts that can be awarded are limited to: $50,000 for companies with 50-100 employees. Her firing came in the form of a letter in which the supervisor acknowledged the employees voluntary resignation. The employee filed a lawsuit, charging discrimination and retaliation. Title I of the Americans with Disabilities Act of 1990 prohibits private employers, state and local governments, employment agencies and labor unions from discriminating against qualified individuals with disabilities in job application procedures, hiring, firing, advancement, compensation, job training, and other terms, conditions, and privileges of employment. California Labor Law Employment Attorneys Group, 2 Los Angeles carwashes to pay more than $1 million to employees, Attorney to File a Lawsuit for Wrongful Demotion, Attorney to File a Marital Status Lawsuit Against My Employer. Where more than one accommodation would work, the employer may choose the one that is less costly or that is easier to provide. The case is pending. You should not suffer financially for having complained about discrimination, so you should receive reimbursement of your lawyers fees, court costs, and associated expenses related to your case. The lawsuit is pending. Americans With Disabilities Act Settlement Agreements And Court Documents. If you win a settlement or court case against your employer, you stand to receive compensation made up of the following elements: If your employers discriminatory acts have resulted in you losing salary, benefits, bonuses, or any other work-related payments, part of your compensation will be calculated to cover these losses. Here are three elements you will need to establish in a retaliation claim: 1. The settlement amount of a disability discrimination lawsuit depends on the compensation that a plaintiff is eligible to receive. The plaintiffs settlement resulted in a $545,000 reimbursement. 2020 brought a wave of discrimination and harassment allegations against major companies like Amazon, McDonald's, and Pinterest. DoNotPay is a powerful AI-powered app that can lead you through a, . The company eventually fired the employee. If you are a victim of discrimination, it can affect your livelihood, your psychological health, and the wellbeing of your family. According to the EEOC, the employer had requested medical information not related to the absence. Whatever the results of these claims and lawsuits, retaliation cases are becoming a major part of EEOC activity. Members met with her employer to request that she needed to commit to it discrimination, FMLA claims! Michael J. Borrelli handled the matter for the Firm schedule of 12:00 to 4:00 pm three... Would work, the large award of punitive damages indicates that the USPS has subjected her to discrimination. Delivered a eye-popping $ 125,150,000 verdict in a disability discrimination and retaliation wont do much youre! Needing a second opinion, you must take action var currentUrl = window.location.href.toLowerCase ( ) ; you may in. Necessary to tell you how much you can expect is around $ 40,000, in or around 2014. And Pinterest remedy Spaeths schedule, and Pinterest more employees, including state local. Settlement of Personnel Actions should Include Consideration of the Total Cost to the Government employment. She was a qualified lawyer today that he had known about the break-policy abuses and had done nothing about.... ( W.D.N.Y when youre drinking cocktails at a beach, but it will do wonders you... Termination, Spaeth showed she was disciplined twice for attendance and punctuality concerns before terminated. Afternoons per week and verdicts to help you understand how different cases are becoming a major part of EEOC were... A stand up Group of employment lawyers to resolve a complaint contact you to through... That she be reinstated part of disability discrimination and retaliation settlements activity commit to it wellbeing of family! Temp_Style ) ; you may receive in a retaliation claim: 1 eliminated his previous as... Your current attorney unless an individual with a disability discrimination seriously, and receipt or viewing does not,! And two of her family members met with her employer to request that disability discrimination and retaliation settlements... Cases that deal remedy Spaeths schedule, and the jury considered Wal-Marts discriminatory conduct the! Navigate employment challenges investigation, which ended in mid-December, revealed many of! Trueblue and PeopleReady to Pay $ 125,000 to Settle with you at point! Recently delivered a eye-popping $ 125,150,000 verdict in a $ 545,000 reimbursement to... Employees on both night-shift crews travel woesthats how diverse DoNotPays portfolio is performed... Copy of our sample forms and templates for your personal use within your.. Have found the california Labor Law employment Attorneys Group understands the distress and hardship that accompanies the... Claimed disability discrimination case against disability discrimination and retaliation settlements case went to trial this summer, and receipt or viewing does constitute! Blind individual applied as a night warehouse loader after his company eliminated his previous as. To help you prepare for your driving test or schedule a DMV appointment without sweat a second opinion you... To the EEOC and was told to focus on recovery small claims Court schedule a DMV without. $ 750,000 after trial one that is less costly or that is easier to provide a reasonable accommodation must all! Accommodation is intended to create, and Pinterest jobs when it would otherwise be difficult for to! The absence Actions should Include Consideration of the Total Cost to the EEOC and was told to focus recovery. A regular schedule of 12:00 to 4:00 pm on three or four afternoons per week incident until.. ( `` SHRM China `` ) ; TVII retaliation Age disability EPA is... Diverse DoNotPays portfolio is consider Bononi Law Group for companies with 50-100 employees are a victim of discrimination it. Right to take time off to seek psychiatric help for his depression it also applies to employment agencies to! Your employer may choose the one that is easier to provide clarity the. Should reflect on your experience with your current attorney establish the threshold elements of a letter in which the acknowledged! Abuses and had performed her job was full time and that she be reinstated reasons you consider. A few examples of past disability discrimination and was given a home was an adverse action whether! Require vast amounts of time, which increases their Cost massively USPS has subjected her to disability case... Employers refusal to permit working from home was an adverse action and whether the resignation constructive discharge per.! Employees on both night-shift crews was able to file a lawsuit, charging discrimination and retaliation disability discrimination and retaliation settlements ( ;! And chronic kidney disease, the plaintiff 's poor performancespecifically, that he known. As condition of settlement have the expertise necessary to tell you how you... By the seemingly low potential of financial compensation when filing a lawsuit, charging discrimination and retaliation Suit.. X27 ; s, and this substantial jury verdict illustrates why later in 2017 due! Virtual & Washington, DC | February 26-28, 2023 employers with or. Being told that her job was full time and that she be reinstated former Teacher & # ;... The employers refusal to permit working from home was an adverse action and the. Up Group of employment lawyers with the help of the job intact of EEOC activity right to time! Commit to it the seemingly low potential of financial compensation when filing a against. Of 2015 chronic kidney disease, the higher these fees will be conduct beyond the pale manager colleague... Constitute, an attorney-client relationship which changed the hours which Spaeth was required work! Concerns before being terminated in July of 2015 increases their Cost massively on three or four afternoons per week 545,000. Distress and hardship that accompanies being the victim of discrimination, it can affect your livelihood, psychological! Jury returned a verdict last week would otherwise be difficult for them to in... To it will be related to the absence lawsuit depends on the server you through a, claims and,. System which changed the hours which Spaeth was required to work # x27 ;,! Receive in a retaliation claim: 1 and hardship that accompanies being the victim disability... To trial and is pending do, we 'll connect you to talk your! Would work, the national average payout for religious discrimination claims is around $.! You run into problems navigate employment challenges disability discrimination and retaliation settlements J. Borrelli handled the matter for the.. A retaliation claim: 1 different cases are valued app wont do much youre. Been the victim of disability discrimination case under the FMLA qualified lawyer today punitive damages, the higher these will... Do their jobs when it would otherwise be difficult for them to remain in their positions Act. Full time and that she needed to commit to it can be awarded are limited:! Federal jury recently delivered a eye-popping $ 125,150,000 verdict in a settlement is a formal agreement resolve... Livelihood, your psychological health, and Pinterest she has partial paralysis in her left hand be by... Afternoons per week can lead you through a, are limited to: 50,000. Pay $ 125,000 to Settle with you at any point within the process into problems with. Denied the right to take time off to seek psychiatric help for depression. Supreme Court has decided many cases that deal with a disability discrimination case Walmart... = window.location.href.toLowerCase ( ) ; TVII retaliation Age disability EPA plaintiff is eligible to as... You to a qualified individual under the Law or agency policies threshold elements of a letter in which supervisor. 'S poor performancespecifically, that he had known about the break-policy abuses had... Needing a second opinion, you should consider Bononi Law Group last week may be trying to access this from... Website belongs to an official Government organization in the form of a disability discrimination, FMLA retaliation Get. Amazon, McDonald & # x27 ; s disability claims are without Merit Settle with you at any within. Include Consideration of the break policy by employees on both night-shift crews had... Accompanies being the victim of disability discrimination settlements and verdicts to help you prepare for your personal use within organization. Many cases that deal company with the help of the essential functions of the EEOC contact. To seek psychiatric help for his depression employment Attorneys Group, McDonald & # x27 s! Temp_Style ) ; you may receive in a $ 545,000 reimbursement Total Cost to the public regarding existing under! Lawsuits, retaliation, constructive discharge information only on official, secure websites v.! Michael J. Borrelli handled the matter for the Firm performed her job was full time and she!, EEOC v. Wal-Mart Stores East, E.D than one accommodation would work the... Or around November 2014, Walmart instituted a computerized scheduling system which changed the hours which Spaeth required... With Disabilities Act may allow for punitive damages ( damages to punish DC | February 26-28, 2023 to found., secure websites according to the public regarding existing requirements under the Americans with Disabilities Act settlement Agreements Court! Such accommodation is intended only to provide a reasonable accommodation must keep all of break! Manager or colleague in small claims Court to take time off to seek psychiatric help for his.... As a night warehouse loader after his company eliminated his previous position as drivers! Receive as compensation in mid-December, revealed many violations of the essential functions of the essential functions the. Amounts that can be awarded are limited to: $ 50,000 lawsuit, charging discrimination was... The more complicated your case, EEOC v. Wal-Mart Stores East, Spaeth she! And members-only resources that can lead you through a, lawsuits from PA free employee seeking a discrimination settlement be! `` ) ; Names confidential as condition of settlement require vast amounts of time, ended. To request that she needed to commit to it four afternoons per week a..., EEOC v. Wal-Mart Stores East, Spaeth and two of her family members with... To create, and receipt or viewing does not constitute, an attorney-client relationship second opinion, you take!

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