To avoid summary judgment, the nonmoving party "must do more than simply show that there is some metaphysical doubt as to the material facts." Matsushita Elec. Based on available information, SMART ALABAMA, LLC will take appropriate action and communicate on a need-to-know basis. The administrative office area, which includes the Human Resources Department, is to the left of the reception area. were deficiencies in Plaintiff's job performance and stated that her employment "from within the safety department" was terminated. Fran Hughes ("Hughes") did some work for the Human Resources Department, although her desk was in the production office area. Despite believing that the letter terminated her employment with Defendant, Plaintiff continued to come to work until February 7, 2006. The testimony provides little detail about what else Plaintiff told Hughes in this conversation. At least two weeks later, on February 2, 2006, Plaintiff wrote the complaints by hand in a letter to Hughes. The typed version of the letter is not in the record, but the hand written draft is before the Court. In her deposition, Plaintiff stated that the letter contained "everything that (Id. The letter references the "sexual harassment situation with Rance Maddox," but does not provide details about Maddox's conduct. This page lists public record sources in Crenshaw County, Alabama.
Plaintiff recounted the missing portions of the letter in her deposition: A: Well, that was just the start of it. I was trying to show, you know, in the letter, you know, I'm not going to work for him, you know, I'm not that type of person. In Plaintiff's deposition, she recounted what she told Kwon at this meeting: A: About him calling all hours of the day and night, about him showing up where I eat, about him asking me out, about him touching me inappropriately, about him telling me to just work with him and you know, everything about how I'd cry, about how I'd throw up, and how it's causing me problems at home.
On January 18, Plaintiff typed a letter to Maddox on a computer in the safety office. It's like Jekyll and Hyde, either you play along or I'm not going to play nice. Plaintiff gave copies of the complete letter to Maddox and Sport.
Only the first four sentences of the letter are in the record, and they state only that Plaintiff has had "a couple of hit and miss days of training," and that Plaintiff has "learned a lot" and is "still learning every day." (Doc. A: The jokes that he made about women and this and that and the other and the little comments and the way that he would invade your space and then, you know, try to be all nice to you in an inappropriate way and then turn around when you wouldn't go along with him and snap at you. The portion of the letter in the record does not mention anything related to sexual harassment. On January 30, 2006, the same day she found the termination letter, Plaintiff met with Antoine Kwon, the director of the plant, for about thirty minutes.
Sport asked her to write a letter to Maddox that addressed all of her complaints.
Sport said that he would talk to Maddox about Plaintiff's complaints after Maddox received the letter.
"An issue of fact is `genuine' if the record as a whole could lead a reasonable trier of fact to find for the nonmoving party.