Tuens

BACKGROUND

In May 2016, Tuens was hired as a “Senior Wealth Strategist/Director” by the Ascent division of U.S. Bank. Ascent

1 All undesignated statutory references are to the

Government Code. serves individuals and families of significant wealth and has selective requirements for prospective clients, including that they have a net worth of at least $75 million and generate a minimum of $200,000 in annual fee revenue. Tuens’ employment history reflects her significant experience in new client acquisition, and her primary responsibility at the Bank was similarly to secure new clients for the division. In October 2015, prior to her hire, Tuens submitted a proposed business plan to the Bank showing that she planned to secure, from her current contacts, three new clients within the first six months of employment, and an additional three clients during the next six months, for a total of six clients in the first year. According to the plan, her “pipeline” showed four possible new clients, and she estimated $300,000 net revenue in the first six months, with about $600,000 to $650,000 of revenue in the first year. In December 2016, Tuens suffered from a catastrophic illness that…