Barnum f. Paul Ryan Associates CA1/2

FACTS

Respondent Terrence Barnum, who at the time of suit had 45 years of experience in the construction industry, was hired by appellant Paul Ryan Associates (Ryan), a general contractor, in December of 2007. According to Barnum’s first amended complaint, Barnum’s primary responsibility during the four years he was employed by Ryan was supervision of its employees’ work and that of its subcontractors on particular jobsites to insure Ryan’s projects were completed timely, safely, economically and in compliance with the plans and specifications. Throughout his employment at Ryan, Barnum assertedly “performed in an exemplary manner, receiving commendations and

1 accolades from management and clients. By 2011, Barnum believed he was the oldest field employee working for Ryan.” That year, a client of Ryan sued the company and others alleging construction defects, mismanagement, and safety hazards at a large scale residential renovation project in San Francisco, and counsel for the plaintiffs in that case required Barnum to appear for deposition regarding his knowledge of the factual allegations. At a meeting convened prior to the deposition by Ryan’s attorneys, Barnum indicated his…