Sample. Facts and figures are illustrative and describe no real person or employer. The structure, assumptions and limits are exactly what a delivered memo contains.

Settlement Analytics Memorandum

Economic loss from wrongful termination — back pay and front pay with stated uncertainty

To	[Counsel], [Firm]
From	Karim Souidi, M.Sc. (Econometrics), NorthLaw.ai
Matter	[Plaintiff] v. [Employer] — sample file NL-2026-0003 (wrongful termination / retaliation)
Date	25 September 2026
Purpose	Settlement and mediation support. Privileged; prepared at the request of counsel. Not prepared for filing or testimony.

1. Bottom line

The plaintiff, a 47-year-old regional sales manager earning $170,000 in base and average bonus, was terminated on 1 March 2025 and re-employed on 1 January 2026 at $118,000. Economic loss to a 1 September 2026 valuation date (back pay) is $215,000 including benefits. Future loss (front pay) depends almost entirely on one assumption, how long the $52,000 annual shortfall persists:

Front-pay scenario	Present value	Total loss
Shortfall closes over five years (plaintiff catches up)	$174,000	$389,000
Shortfall persists to statistical work-life (age 62), adjusted for the probability of continued employment	$552,000	$767,000
Shortfall persists to work-life, no attrition adjustment (plaintiff's likely framing)	$736,000	$951,000

A defensible settlement range is $390,000 to $770,000; the upper figure without attrition adjustment is unlikely to survive cross-examination. The single fact most worth developing is the plaintiff's realistic path back to a comparable role, because it decides which row applies.

2. Question presented

What the plaintiff lost in earnings and benefits as a result of the termination, net of mitigation, from termination to the valuation date and into the future, with the uncertainty stated.

3. Facts relied on

Item	Value	Source
Date of birth / age at termination	1978 / 47	Counsel
Pre-termination base salary	$142,000	W-2s 2022 – 2024
Average annual bonus (3 years)	$28,000	W-2s, bonus letters
Employer benefits (health, 401(k) match, LTD)	22% of cash compensation	Benefits summary; BLS ECEC as cross-check
Termination date	1 March 2025	Termination letter
Re-employment	1 January 2026 at $118,000 base, no bonus, comparable benefits	Offer letter
Valuation date	1 September 2026	Counsel (anticipated mediation)

4. Results

Back pay (1 March 2025 – 1 September 2026). Ten months with no earnings: $141,700. Eight months at the new job: shortfall of $52,000/year × 8/12 = $34,700. Subtotal $176,400; with benefits at 22%, $215,200. No offset for unemployment insurance is taken (collateral-source treatment varies by jurisdiction; counsel to apply).

Front pay (from 1 September 2026). The annual shortfall is $52,000 in cash plus 22% benefits. Its present value depends on duration, wage growth (3.0%/year, both jobs) and the discount rate (4.8%, 10-year Treasury plus a small premium). The chart shows how the total moves with the duration assumption.

Figure 1. Solid line: shortfall persists for the years shown, no attrition adjustment. Dashed: adjusted for the statistical probability that employment with the former employer would have continued. The catch-up scenario assumes the shortfall closes linearly over five years.

5. Where the estimate is strong and where it is exposed

Strong: back pay is documentary; the only judgment is the benefits rate, cross-checked against BLS data. The re-employment offer letter fixes the mitigation figure.
Exposed: front pay to work-life assumes the plaintiff never recovers a comparable role. At 47 with a sales-management record, that is the least likely path; the employer's expert will say so and will be right to. The attrition adjustment is standard and should be conceded rather than argued.
Bonus: the $28,000 average includes an unusually strong 2023. Using the median ($24,000) lowers every figure by about 3%; counsel should be ready for the question.
Mitigation: the ten-month job search is within the range for the plaintiff's occupation and region (median 6 – 9 months for sales management at this level); the employer may still argue for a shorter reasonable period.

6. Limits of this analysis

Front pay is inherently an assumption about the future; the scenarios bound it, they do not predict it.
Non-economic damages, emotional distress, punitive damages, prejudgment interest and tax gross-up are outside this memo.
Facts were supplied by counsel and, except where noted, not independently verified.
Prepared for settlement discussions; not an expert report under FRCP 26(a)(2)(B).

Karim SouidiM.Sc. Econometrics · DASCA Senior Data Scientist · NorthLaw.ai · karim@northlaw.ai

Appendix A — Technical results

Table A1. Assumptions and sources.

Parameter	Value	Basis
Wage growth, both positions	3.0%/yr	BLS Employment Cost Index, management occupations, 10-year average
Discount rate (nominal)	4.8%	10-year Treasury at valuation date + 0.5% premium
Net discount rate	≈ 1.75%	(1.048 / 1.030) − 1
Benefits load	22%	Employer benefits summary; BLS ECEC private-industry management ≈ 30% including legally required
Work-life expectancy, age 47 male, college degree	to age ~62 (≈ 13 years from valuation)	Skoog-Ciecka-Krueger work-life tables (2019 update)
Annual probability of continued employment with former employer	declining from 0.92 to 0.60 over horizon	Employer tenure distribution for comparable roles; JOLTS separations as cross-check

Table A2. Front-pay present values by scenario.

Scenario	Years	PV cash	PV incl. benefits
Catch-up, linear over 5 years	5	$143,000	$174,000
Persistent shortfall, no attrition	13	$603,000	$736,000
Persistent shortfall, attrition-adjusted	13	$452,000	$552,000
Persistent shortfall, attrition-adjusted, 8-year horizon	8	$318,000	$388,000

A3. Sensitivity. Each 1-point change in the net discount rate moves the work-life scenarios by about 7%. Using the median bonus lowers all figures by 3%. A 30% benefits load (BLS all-in) raises them by 6.5%. Assuming a 12-month rather than 10-month job search adds $28,000 to back pay.

A4. Method. But-for earnings path from documented compensation grown at 3.0%; actual earnings path from the offer letter grown at the same rate; loss = difference, discounted to the valuation date at 4.8%, with benefits at 22% of cash. Attrition adjustment multiplies each year's loss by the cumulative probability of continued employment. Work-life from published tables by age, sex and education. Calculations are in a spreadsheet available to counsel.

Appendix B — Data

W-2s 2022 – 2024; bonus letters 2022 – 2024; employer benefits summary (2024 plan year); termination letter dated 1 March 2025; offer letter from new employer dated 12 December 2025; plaintiff's job-search log (counsel-provided). Public sources: BLS ECI and ECEC, JOLTS, U.S. Treasury yields, Skoog-Ciecka-Krueger tables. Facts not independently verified except against the documents listed.