A trial brief is typically prepared and provided to the Judge and theopposing party, which sets forth various aspects of the case and whatwill be presented at trial. Different jurisdictions have different rulesas to when the brief must be filed and what it must contain.

Your supervising attorney, Janie Lynch, has prepared a portion of atrial brief for an upcoming trial; she has entered the case law and heranalysis of the law, attached here.

However, she would like for you to prepare the factual section of thebrief from her notations below (which are rather unorganized), and toformat a section regarding the names of the witnesses to be called. Shewould like to include all witnesses who are named in her notes below, orin the analysis section of the brief.

• In August of 2014, Mr. Smith was terminated, and contained in the termination notice were numerous false allegations.
• As a result of the false allegations, the surroundingcircumstances of harassment of Mr. Smith and his termination, Mr. Smithfiled suit against Apple Pie, alleging defamation.
• Smith was employed (for the second time, and the time periodpertaining to this matter), by the Apple Pie Company as a Counselor, onor around May 18, 2008, until his termination on August 25, 2014.
• During his employment with Apple Pie, Smith witnessed numerous ethical violations and concerns.
• He followed correct procedure by filing four complaints over his concerns.
• Included in the termination notice were numerous false statements pertaining to Smith.
• The complaints pertained to ongoing issues with Ms. Brown, Smith's supervisor, and issues with the Apple Pie.
• Mr. Smith was accused of engaging in a personal relationship with a client.
• Mr. Smith did not engage in any personal relationships with clients outside of work.
• As a part of his employment, Smith attempted to act in the bestinterest of the clients of Apple Pie; when clients were concerned thattheir grievances against other Apple Pie employees were not beingresponded to or handled, Mr. Smith obtained signed releases from thoseclients to aid them by further looking into their complaints.
• Each release was obtained as the result of a concerned client.
• On August 6, 2014, a meeting was held where Ms. Richards, ApplePie President, falsely accused Mr. Smith of failing to respond to arumor of a client bringing a gun onto Apple Pie property; Mr. Smith wasnot even working on the day in which he allegedly knew of the gun.

You should also review the entire brief for spelling and grammarissues, as well as correct instances in which names are misspelled, theDefendant's name is in all capitals, etc.