Notice of client retention by Joni Thome to Thomas Moran
Letter to West Group VP of Human Resources from counsel retained by Complainant (Plaintiff)
- Equal Employment Opportunity — Restatement of Company Policy
- West Group Harassment Policy
- West Group employee relocation package
- Email thread: Lewis Freeman and Julienne Goins
- Email thread: Joan Tarbox and Julienne Goins
- Email letter to multiple parties
- Email thread: Jennifer Davis and Julienne Goins
- Email thread: Janis Walworth and Julienne Goins
- Email thread: JoAnna McNamera and Julienne Goins
- Plaintiff Series of Events Journal
- Email thread #1: Tami Becker and Julienne Goins
- Email thread #2: Tami Becker and Julienne Goins
- Formal resignation from West Group and the Thomson Corporation
- Notice of client retention by Joni Thome to Thomas Moran
- Minnesota Department of Human Rights Questionnaire Package
- Handwritten notes by the Plaintiff, August 1998
- Post letter from Julienne Goins to Joni Thome
- Letter from Julienne Goins to Joni Thome, estimating Defendant liability
- Letter from Joni Thome to Julienne Goins, requesting Complaint review
- Letter from Julienne Goins to Joni Thome, with amended Complaint draft
- Plaintiff Complaint
- Defendant’s Answer and Affirmative Defenses
- Scheduling Order, Judge Franklin J. Knoll
- Defendant Notice of Taking Deposition of Julienne Goins
- Defendant’s Interrogatories to Plaintiff (Set I)
- Defendant’s Request for Production of Documents (Set I)
- Plaintiff’s Response to Defendant’s First Set of Request for Documents
- Defence deposition of Julienne Goins (Vol. I)
- Deposition correction sheet
- Defendant Memorandum of Law in Support of Motion to Compel
- Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion to Compel
- Notes from Plaintiff deposition of Jim Joseph
- Notes from Plaintiff deposition of Lewis Freeman
- Order and Memorandum by Judge Thomas W. Wexler Granting Summary Judgement Dismissal
- Statement of Account — Costs, Disbursements and Expenses
- Court of Appeals Decision
- Brief of Amici Curiae: Minnesota Employment Law Council and Minnesota Chamber of Commerce
- Respondent’s Brief
- Brief of Amici Curiae: Outfront Minnesota and Minnesota Lavender Bar Association
- Brief of Amici Curiae: National Center for Lesbian Rights, Gay & Lesbian Advocates & Defenders, Employment Law Center, Harry Benjamin International Gender Dysphoria Association
- Plaintiff notes during hearing, 3 May 2001
- Supreme Court Opinion
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Joni M. Thome
Attorney at Law
416 East Hennepin Avenue
Minneapolis, Minnesota 55414
Tel.: 612/379-5307
Fax: 612/379-5316
February 4, 1998
Thomas Moran
Human Resources
West Group
610 Opperman Drive
Eagan, Minnesota 55123
Re: Julienne Goins
Dear Mr. Moran:
I have been retained to represent Ms. Goins in matters related to her employment with West Group. As you may know, Ms. Goins resigned from her employment with West effective January 23, 1998.
Prior to her resignation, Ms. Goins made several attempts to resolve issues of hostile and discriminatory treatment imposed upon her during her employment at West. Despite her efforts, the issues were not resolved in a timely and appropriate manner. Ms. Goins felt she had no alternative but to leave the hostile and discriminatory work environment.
Ms. Goins first provided Mr. Lewis Freeman with her complaint of sexual orientation discrimination and harassment after he mandated that she, because of her sexual orientation, be restricted to the use of one bathroom facility in the office complex. Ms. Goins then made her complaint known to Ms. Tami Becker of the Rochester office. It is my understanding that Ms. Tami Becker and Mr. Joe Hicks met to discuss Ms. Goins complaints and those complaints were then relayed to you by Mr. Hicks.
Ms. Goins provided Ms. Becker and Mr. Hicks with a written chronology and narrative of events and incidents that describe the discriminatory and harassing treatment along with copies of e-mail exchanges. While that chronology and narrative is not intended to relay every incident or event that gives Ms. Goins basis’ for her claims of discrimination and harassment, they do provide a good summary of the events that support her claims. (If you do not have copies of the documents referenced above, please contact me and I will forward them to you)
Ms. Goins believes she was treated in an illegal, discriminatory and harassing manner by employees of West Group. After reviewing the above-referenced documents and extensive interviews with Ms. Goins, I have advised her that she does, in fact, have strong claims of sexual orientation discrimination and harassment under the Minnesota Human Rights Act.
I have advised Ms. Goins with regard to her legal rights and options. Ms. Goins is willing to discuss a resolution in this matter but is prepared to take legal action should the need arise. Please contact me, or have your legal counsel contact me so that we can begin to work toward resolution. If I do not hear from you or your legal counsel before February 18, 1998, I will assume West Group is not interested in discussing resolution prior to litigation. I look forward to working with you to resolve this matter.
Very truly yours,
[signature]
Joni M. Thome
cc: Julienne Goins
