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Emma Simpson Argumentative Essay

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Plaintiff, Emma Simpson worked for defendants, Pioneer Partners and Jenny Martinez, for several years, before she was terminated. Jenny Martinez Dep. 4:14–18. The defendant, Jenny Martinez, is the CEO of Pioneer Partners, a multi-million-dollar corporation. Jenny Martinez Dep. 4:8. In late January 2016, Ms. Simpson’s mother, Collen Simpson, was diagnosed with a fatal disease, Creutzfeldt-Jakob disease. Emma Simpson Dep. 9:1. Ms. Simpson learned that her mother had very little time left and that the disease was deteriorating her mother’s health very quickly and included degenerative symptoms such as dementia; personality changes; depression; mood swings; difficulty sleeping or swallowing; and sudden, jerky movements. Id. In general, 90 percent of people who suffer from Creutzfeldt-Jakob disease die within one …show more content…

Matthew Hall Aff. 2. In April 2016, Ms. Simpson requested leave under the FMLA and it was granted. Justin Merritt Aff. 5. The leave request was only for a week. Emma Simpson Dep. 9:21. Ms. Simpson applied for the leave in order to provide care for her dying mother. Emma Simpson Dep. 5:8. After being granted leave, Plaintiff travelled with her mother to California. Compl. 19. Prior the trip Mrs. Simpson’s doctor, Allison Rowbury, urged Ms. Simpson to accompany on her mother on her trip in order to monitor and care for her mother, because on multiple occasions Ms. Simpson’s father forgot to give Mrs. Simpson her medications. Allison Rowbury Aff. 1–3. Dr. Rowbury knew that if Mrs. Simpson failed to receive her medication, Mrs. Simpson would experience not only tremendous pain but also be essentially incapacitated.

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