JENNIFER SMITH,

Plaintiff,

v.

OLD AGE METALS,

Defendant.

(Names have been changed)

PLAINTIFF’S MEMORANDUM IN OPPOSITION TO DEFENDANT’S SUMMARY JUDGMENT MOTION

5. Timing of Firing and the Totality of these Circumstances

Finally, taken together, the timing of Plaintiff’s firing and all of the circumstances detailed in sub-sections 1 through 4, demonstrate that a causal connection exists between Plaintiff's protected activity and her firing. Unlawful retaliation has been established. Defendant’s summary judgment motion should be denied.

VI. CONCLUSION

For the foregoing reasons, Defendant’s motion for summary judgment should be denied.

Respectfully submitted,

JENNIFER SMITH

/s/ Ronald B. Schwartz

Ronald B. Schwartz
Katz, Friedman, Eagle, Eisenstein,
Johnson & Bareck P.C.
77 West Washington Street, 20th Floor
Chicago, Illinois 60602-2983
(312) 263-6330

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Revised: 9/20/2008

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