Thumbnail Brief CITATION: Brown v. Hammond, 810 F. Supp. 644 (E.D. Pa. 1993) FACTS: Brown was a paralegal employed by Hammond when she "blew the whistle" on fraudulent billing practices and was subsequently mistreated then terminated. Brown sued for unlawful termination but was an at-will employee, and Hammond filed a Rule 12(b) (6) Motion to dismiss. ISSUES: Are there legally sufficient facts pled to support the relief sought in the Complaint? Does forced illegal activity overrule the precedent to base rulings on gratuitous v. mandated disclosure? HOLDING: NO AND YES REASONING: Count 1 - In Pennsylvania, the only recognized cause for wrongful discharge action is where it "violates a significant and recognized public policy". Borse v. Piece Goods Shop, Inc., 963 F.2d 611 (3d Cir. 1992), as amended (May