that he is forced to quit involuntarily.” Terry v. Ashcroft, 336 F.3d at 151-52 (and cases cited therein). Case láw generally focuses on two parts of this standard: the employer’s intentional conduct and the intolerable level of the work conditions. Focusing first on the intent requirement, we recognize that in some constructive discharge cases, plaintiffs have been able to establish that employers acted'with the specific intent to prompt employees’ resignations. See, e.g., Kirsch v. Fleet Street Ltd., 148 F.3d 149, 161-62 (2d Cir.1998) (upholding jury finding of constructive discharge where evidence indicated that employer nodded affirmatively when plaintiff suggested that the company was trying to force her to leave); Lopez v. S.B. Thomas, Inc., 831 F.2d 1184, 1188 (2d Cir.1987) (<HOLDING>), prompting some district courts in this
holding that an attorneys performance was deficient because he failed to investigate and reasonably select the   defense used at trial holding that an employee might be entitled to overtime where he was told that he would not be paid overtime but was not told to limit his hours holding constructive discharge supported by evidence that supervisor told employer he would be fired at the end of a  probationary period no matter what he did to improve his allegedly deficient performance holding that a hospital employee could not be convicted of terroristic threats after he told one of his supervisors that he wanted a transfer because he felt like killing another supervisor and wrote a letter to human resources to that effect because he went out of his way to avoid contact with the supervisor he disliked and clearly did not intend for the letter to be delivered to her holding that employer was entitled to discharge employee after he threatened life of his supervisor even if such misconduct was caused by employees disability