At $8$:$01$ a$.$m$.$ on your first day as the new VP of HR$,$ three female employees complain of harassment by their manager. They allege that he $(1)$ exposed himself, $(2)$ groped them and $(3)$ forced them to participate in a $$smooching club$$ to get sales leads.

You discover that the company has no anti$-$harassment policy, training or reporting procedures. Then you learn that the alleged harasser just fired the complaining employees before you were able to do anything about it$.$

The Lawsuit

In depositions, the manager offers nothing helpful and testifies that anti$-$harassment procedures are unnecessary. Your deposition goes OK but when you$$re asked to state the legal definition of harassment, you freeze and then offer a convoluted $87-$word sentence that$$s only about $38\%$ correct.

The Question

After the depositions, the employees$$ lawyer offers to settle for $$1\mathrm{.}2$ million $$ no negotiating, take it or leave it$.$