Initial Summary

This witness statement presents multiple potential legal claims arising from what appears to be a deliberate and discriminatory termination of Mr Nuno following his disclosure of mental health conditions. The most significant claims include constructive discharge, ADA discrimination and retaliation, intentional infliction of emotional distress, and breach of implied employment contract. The facts strongly suggest that Ron Suarez manufactured a hostile situation to force Mr Nuno’s resignation after learning about his mental health conditions and trauma history.

I. Factual Pattern

Key Facts:

• Unpaid Labor: Mr Nuno performed over $10,000 worth of professional work without compensation1
• Housing as Primary Compensation: Initial agreement was housing-for-work with future salary1
• "Our Home" Representation: Ron referred to the property as "our home" — implying decided tenancy of Mr Nuno in Mr Suarez’s home1
• Forced Departure During Medical Crisis: Mr Nuno explicitly stated "I am feeling threatened"1
• Multiple Intimidators: Ron brought multiple people to confront Mr Nuno during panic attack1
• Stranded Without Support: Mr Nuno was left stranded in unfamiliar city, forcing expensive emergency travel1
• Father's Damages: Mr Nuno's disabled father also suffered losses from aborted relocation1
• Ron's Bad Faith: Ron claimed to feel “very scared” and "vulnerable" by Mr Nuno’s reaction to his question (i.e. refusing to answer the question regarding legal matters, informing him the information had been provided in writing, and communicating a medical emergency that required him to leave the room) despite orchestrating the confrontation1

II. Wage and Hour Claims

A. Quantum Meruit / Unjust Enrichment

Under Michigan law, quantum meruit applies when valuable services are provided with the expectation of compensation123. Mr Nuno has an exceptionally strong claim:

Elements Satisfied:

1. Valuable Services Provided: Over $10,000 worth of work including business plans, team leadership, and infrastructure improvements1
2. Services Accepted: Ron utilized Mr Nuno's work product and expertise1
3. Expectation of Payment: Clear understanding of $130,000/year compensation1