Order Description

Assignment structure is writing Memorandum of Law about my case .
Structures are :
1-Conclusion – from my case which is 4 page
2-Rule -from my case
3-Rule Proof from two Cases : (A- Conclusion B-Fact C-decision )
First case/ CYNTHIA D. TRAYLOR v. KIRK BROWN
(A- Conclusion B-Fact C-decision )
Second case / EMILY BRYSON, Plaintiff-Appellant, v. CHICAGO STATE UNIVERSITY (A- Conclusion B-Fact C-decision )

4- Rule Analysis : For these two cases and compare between them and my case
and writ what is similar to my case and why
and what it is not similar and why

RE: Dr. Ossama Mohammed / TitleVII Claim
The following information summarizes an interview I had with a gentleman named Ossama Mohammed in my office yesterday. You will find your instructions at the end of

this memo.
Dr. Ossama Mohammed is an Iraqi-American who has been living in the United States for nearly 35 years. He has been a citizen for 28 years. Dr. Mohammed, like most

Americans, likes to talk on a first-name basis. He asked me to call him “Sam,” like all his friends do.
Sam got his Ph.D. in chemical engineering at the Illinois Institute of Technology (“IIT”) in 1985. He then went to work as a researcher at Ingredion Incorporated

(f/k/a Corn Products International, Inc.), at its world headquarters in Westchester, Illinois. He has been working there ever since. You can tell the guy is still a

foreigner only because he is so loyal to his employer. He told me that headhunters have contacted him many times over the years but that he would not even consider

leaving Ingredion. He loves – or loved – his work.
Sam does not even take most of the vacation time accruing to him, he told me. Last year he took a month when his sister got married in Dubai. He spent three weeks

there, he told me, and then stopped off in London on the way home to see some old friends. He had two months accruing to him even then, though. He put everything
Sam Mohammed – Assigning Memo – Page 2 of 4
through with H.R. and had no problems getting the time, at all. Other than that, Sam rarely takes time off. He does not travel extensively, other than for work. He is

consumed by the enormity of his research projects. He was telling me all about the various enzymes and bacteria found in termites’ stomachs. Needless to say, I didn’t

know what he was talking about, or why that might be important. He told me that termites eat and digest corn stalks. I had to keep coming back to what Ingredion had

said and done to him, which I describe below. There was a lot of stop and start because this guy is a bona fide distracted genius type.
Ingredion is a Fortune 500 company. It has over 11,000 employees worldwide and does business in over 100 countries. Its shares are listed on the New York Stock

Exchange. Ingredion recently changed its name from Corn Products, but has not changed its activities or any of its key players.
During his 29-year career at Ingredion, Sam has worked on many of the company’s high-value research projects. He spent over five years in GMO research before

transferring to the ethanol group. For the past six years, he has been working on a team that is researching a chemical engineering process to obtain motor fuel in the

form of alcohol from corn stalks. Two years ago, he and two full-time IIT professors published a book describing critical discoveries they had made through their

research. Sam and these professors speak at major scientific gatherings at universities and corporate research labs about all this.
Four months ago Sam was transferred to a position as plant inspector, a position that requires only a bachelor’s degree. Instead of working on projects that go to the
Sam Mohammed – Assigning Memo – Page 3 of 4
core value of the company’s stock, Sam now checks that maintenance is completed on schedule. He also checks the automated operations logs to ensure that there have not

been any operational irregularities. The last plant inspector at Ingredion left her position when she got a master’s degree. She then went to work as a junior

researcher at Argonne Laboratories. She did so simply because she had become over-qualified for the plant inspector position. Her new position at Argonne, however, is

still significantly below the one Sam had held at Ingredion before his transfer.
Sam complained to his boss about this transfer. In response, his boss told him that he shouldn’t complain because the company had not reduced his (substantial) salary.

Ingredion had taken this action pursuant to the company’s re-organization, his boss said. Ingredion’s re-organization is not in dispute. After Sam complained, his boss

gave him a new title, though no new duties or growth opportunities. He is now “Chief Plant Inspector.” Sam’s boss is not a scientist. He was originally an engineer,

but then got an MBA and went into management. He and Sam have always gotten along very well and still do. When Sam raised the issue of this transfer with him again

last week, his boss told him: “Everything will be alright, Sam. You’ll see.”
Sam is a scientist. He really didn’t know what to think about his new job assignment, but thought these actions reflected accidental and idiotic managerial actions. He

was going to wait it out, as his boss seemed to suggest he should, until he had lunch with a former colleague a few days ago. Sam’s former colleague, who just retired

from Ingredion, told him that he had heard Sam’s boss’s boss (the “Big Boss”) make numerous remarks filled with racial and religious slurs. It seems that the Big
Sam Mohammed – Assigning Memo – Page 4 of 4
Boss’s son had returned from military duty in Iraq not long ago, where he was seriously injured. Since his son returned, the Big Boss had spoken bitterly of Iraqis and

Arabs. Specifically, in a conversation about a Dubai company that might take over the management of some United States’ ports, the Big Boss allegedly said: “No dirty

Arab had better cross my path, or he’ll be sorry.”
Sam does not know the Big Boss very well. He has only met him a few times, and hasn’t spoken to him in over a year. He hasn’t had any reason to do so, he said. Sam did

tell me that his own boss reports to the Big Boss weekly.
Assignment
Before I call Ingredion’s legal department, I would like you to draft a memo outlining Sam’s position under Title VII and this circuit’s case law. These facts are so

crazy. All I want from you are the federal law claims available to Sam. I have other associates working on the EEOC procedures and the state law issues.
I am sure that Ingredion’s attorneys, whether in-house or outside, have no idea what has been going on. Naturally they will want to settle. I just want to know how

strong our case is so I know what we can demand to make Sam whole.