You have just graduated from Mason and receive a HR position within a prestigious non-profit hospital. Your manager receives a newly filed healthcare employment discrimination case and knows you completed a course in Legal Aspects of Healthcare. She asks you to draft a memo that will educate her about this area of the law and make specific recommendations about issues which may arise in this matter. She asks you to be specific about the requirements to state a prima facie case for all causes of action against the hospital; what defenses may be asserted and how the plaintiff may counter the defenses.

The complainant, Frieda Fedup, alleges the following:

• She worked as a pharmacy manager at Best Hospital from April 2012 until she quit in October 2016. She filed a lawsuit on October 29, 2017.
• The president of Best Hospital is Warren Wolf. It has 55 employees.

She alleges that during her over four years at Best Hospital, Wolf often insulted her because of her gender, made her the target of unwanted sexual innuendos and in the presence of other employees, made statements such as, "You're a woman, what do you know" and "We need a man as the pharmacy manager"; at least once, he told her she was a "dumb ass woman."

Again in front of others, Wolf suggested that the two of them "go to the Holiday Inn to negotiate [Fedup's] raise." Occasionally, Wolf asked Fedup and other female employees to get coins from his front pants pockets and threw objects on the ground in front of her and other women and asked them to pick them up. He frequently commented, using sexual innuendo, about Fedup's and other female employees' attire.

In August 2016, Fedup complained to Wolf about his conduct and he claimed he was only joking and apologized. Based on his assurance he would stop, she agreed to stay on the job. However, in September 2016 while she was arranging a deal with one of Hospital Best customers, Wolf asked her, in front of other employees and her customer, "What did you do, promise the guy some [sex] Saturday night?"

She collected her paycheck and quit October 1, 2016.