Title: Mediation Brief of Defendant YYY Industries, inc.
Contents
I. Introduction
II. Summary of facts
A. Mr. XXX’s Employment and Military Service
B. Mr. XXX’s Waiver of USERRA Rights and Applications for Employment
C. Mr. XXX’s DFEH Complaint
III. Claimant waived his USERRA claim by not timely reapplying for employment
IV. There is no basis for claimant’s disability claim because YYY Industries had no knowledge of any disability
V. Settlement posture
VI. Mediation participants
Word count: 2,188 (7.29 pages)