Based on the forecast miss, you decide to fire the woman. However, if the worker normally does a decent job, and the insubordinate demeanor is a recent affair, then the personnel employees may decide to help the worker. If you do, you'll have greater success in protecting your business from wrongful layoff lawsuits. In addition, if things "hit the fan" with the employee, you will have that in your back pocket. Give the original copy of the employee layoff memorandum to the jobholder while keeping a copy for your records. And, since you forced him to quit, you're open to a illegal layoff suit. Due to company pressures, the Firm is separating your employment effective ________.

Although management should allow personnel time to grieve for their coworkers, they also need to refocus the department quickly on new goals and objectives. Owing to [poor performance, repeated misbehavior, gross misbehavior, excessive absenteeism, excessive tardiness], the Business is terminating your employment effective ________. Later you may revisit the warning if you don't see improvement in the jobholder's behavior. First you give a verbal warning. Also take time to point out company policies and procedures so the worker is made aware of them. Due to her inadequate productivity over the past few months, we've given her warnings with the latest being a final written warning. Even "at will" workers who understand that they may lose their job at any time may have legal recourse if your reasons for separating an employee are invalid. If you ask most sole proprietors and personnel managers the most common reason for dismissing, they will tell you its insubordination.