You have just graduated from Mason and receive a HR position within a prestigious non-profit hospital. Your manager receives a newly filed healthcare employment discrimination case and knows

You have just graduated from Mason and receive a HR position within a prestigious non-profit hospital. Your manager receives a newly filed healthcare employment discrimination case and knows you completed a course in Legal Aspects of Healthcare. She asks you to write a memo that will educate her about this area of the law and make specific recommendations about issues which may arise in this matter. She asks you to be specific about the requirements to state a prima facie case for all causes of action against the hospital only; what defenses may be asserted and how the plaintiff may counter the defenses.
The complainant, Felicity Fedup, alleges the following:
She worked as the Vice President, Pharmacy Manager at Potomac Hospital from April 2015 until she quit in October 2021. She filed a lawsuit on October 10, 2022.
Potomac Hospital has 250 employees.
For the last two years of her employ, she has worked with Wally Wolf, who directly reports to her has the Assistant Vice President, Pharmacy Assistant Manager.
She alleges that during the last year working at Potomac Hospital, Wolf often insulted her because of her gender, made her the target of unwanted sexual innuendos and in the presence of other employees, made statements such as, “You’re a woman, what do you know” and “We need a man as the Vice Predident”; at least once, he told her she was a “dumb ass woman.”
Again in front of others, including members of the hospital’s leadership team, Wolf suggested that the two of them “go to the Motel 6 to negotiate [Fedup’s] raise.” Occasionally, Wolf asked Fedup and other female employees to get coins from his front pants pockets and threw objects on the ground in front of her and other women and asked them to pick them up. He frequently commented, using sexual innuendo, about Fedup’s and other female employees’ attire.
In June 2021, Fedup complained to Wolf about his conduct and he claimed he was only joking and apologized. Based on his assurance he would stop, she agreed to stay on the job. However, in September 2021, while she was arranging a deal with one of Potomac Hospital’s customers, Wolf asked her, in front of other key employees and her customer, “What did you do, promise the guy some sex?”
Fedup collected her paycheck and quit October 1, 2021.