Plaintiff's Trial Brief: Evidence of Similar Incidents Is Relevant and Admissible

CAUSE NO.

[STYLE]

TO THE HONORABLE JUDGE OF THE COURT:

Defendant requests this court to limine out evidence relating to other employee’s complaints or claims against the Plaintiff’s supervisor and/or the Defendant. The type of evidence Defendant seeks to exclude is relevant and admissible. Further, Defendant’s primary authority does not stand for the proposition for which Defendant suggests.

Defendant cites Hirase-Doi v. U.S. West Communications, Inc., 61 F.3d 777, 782 (10th Cir. 1995) for the proposition that the only evidence which may be relied upon is of instances of harassment directed towards the Plaintiff. However, Defendant...