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Draft a letter to our client, Ms. Rey's friend and co-worker, Mazzie Kanata, telling her that she will be subpoenaed to testify for Ms. Rey.

Draft a letter to our client, Ms. Rey's friend and co-worker, Mazzie Kanata, telling her that she will be subpoenaed to testify for Ms. Rey. You know she will be a hostile witness who does not want to testify. So, keep it short and to the point. You do not have to cite law in this letter, but you can if you think it is applicable. You can make up the name of the law office for the letterhead. Make sure you use formal letter format.

Case Facts:

Your client, Rey Star worked is an administrative assistant for the Utilities and Housekeeping Department at Station Hospital. Her manager was Hans Soro. Hans was divorced and a pillar of the community, doing volunteer work at the local foodbank. His record at work was clean up until this situation with Rey. At the holiday office party, Hans jokingly kissed Rey under the mistletoe. She laughed about it. Her friend and co-worker Mazzie Kanata saw this. Hans and Rey sometimes went out to lunch and he would "playfully" try to hold her hand and tell her how pretty she looked. Rey thought they were just friends. They went out at night a number of times to a movie and dinner but after six months of this, Rey was uncomfortable and decided she did not want to pursue a relationship. Hans was not happy. He would bump into Rey when she walked by him at work or put his hands on her shoulders when he gave her assignments. Sometimes he told her how sexy she looked. Once when Rey was walking by, she heard him laughing with a janitor, Luke Walker, from their department, telling Luke about how Rey had a "bIg butt and she knew how to use it." Hans gave Rey a poor performance evaluation, although it was true Rey was late every now and then. Rey told her friend and co-worker, Mazzie Kanata stories about Hans. Mazzie said that Hans had also "flirted" with her but she put a stop to it since she (Mazzie) was engaged. After she told Hans to stop, he did. Mazzie loves her job at Station Hospital but she saw how upset her friend Rey was during this time and offered her consolation.

After a year of this, Rey went to HR to complain and Leia Prince, the head of HR promptly started an investigation. Leia followed up with Rey on a weekly basis through telephone calls. After an internal hearing, HR took steps to prevent and correct the sexual harassment in the workplace by offering Rey a job in another department for the same pay. Rey refused to take that job, as the hours were different (evenings) and she liked her daytime job. She kept the daytime job for another three months. Nothing changed. Hans continued to touch her inappropriately or make untoward comments.

Finally, Rey told HR to forget it and she would take care of it on her own. Ultimately, Hans Soto was reprimanded by a note in his file stating that he should not go out socially with his staff. This caveat that there was to be no social interaction between managers and staff was added to the Employee Handbook (but it was not in the handbook during the period mentioned in this fact pattern). Nothing else happened to Hans. After three months, there were layoffs in the business due to an economic downturn, according to Station. Three out of 25 people got laid off in the department and Rey was one of them. Rey comes to your office asking whether she has a case against Station Hospital. Your boss thinks there may be a case for wrongful termination. He wants to advocate for Rey to get her job back.

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