may have been paid to Ms. Flockhart. As a management support person, Ms. Flock-hart was entitled to participate in IBP’s 401(k) Plan and receive bonuses and other fringe benefits. The Court finds that a 25% figure is a very conservative estimate of the value of those benefits to her. The Court will then deduct from total gross wage loss the total amount of earnings received from other employment since Ms. Flockhart’s constructive discharge. IBP claims that Ms. Flockhart has failed to mitigate damages in this case. See Excel Corp. 165 F.3d at 639 (“A Title VII claimant seeking either back pay or front pay damages has a duty to mitigate those damages by exercising reasonable diligence to locate other employment ... ”). The Court finds that IBP has failed to prove that defense. See id. (<HOLDING>). Ms. Flockhart suffered severe emotional
holding that the burden of proving divisibility in a cercla action is on the defendants holding that the burden of proving that the employee did not make reasonable efforts is on the defendant holding that the burden is on the plaintiff holding that the defendant bears the burden of proving outside contact with the jury holding that the burden of proving lack of negligence is on the owner