Draft a RIF rationale memo that survives discovery
This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
Business reason, scope, cost-out target, timing, and the decisional unit.
Ranked criteria with weights, plus the date they were fixed and who set them.
Counts by protected class for the decisional unit and the selected group. Ranges are fine if exact figures are sensitive.
Where the affected employees work, plus any state RIF or plant-closing statute in play.
Anyone selected who is on leave, recently complained, near retirement, or otherwise sensitive.
Watch for these throughout
Run the adverse-impact analysis under counsel's direction and label it accordingly. An HR-run analysis sitting in a shared drive is usually discoverable, and it is the first thing plaintiff's counsel asks for.
The OWBPA § 626(f)(1)(H) disclosure is mandatory for group separations of employees 40 and older, and a defect voids the ADEA release for everyone who signed.
The model will do the four-fifths arithmetic quickly and sometimes wrongly. Recompute every ratio and the standard-deviation figure before the memo goes to the GC.
Selecting someone who recently took protected leave or filed a complaint requires contemporaneous documentation that the rationale predates the activity. If that document does not exist, the memo cannot manufacture it.
Federal WARN and state analogues run on their own clocks and headcount triggers. Confirm the notice obligation independently. The memo's timeline assumes it has been handled.