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• You can add any extra PDF files, pages, and annotations to the existing PDF file.N’Djamena, Chad — At his rally in this capital, Chadian President Idriss Deby said the United States should have remained in the African Great Lakes region. According to the International Crisis Group, the United States is currently the only power that could hold him accountable for human rights abuses and protect civilians against his forces in Chad’s Borkou and Djera region.

On July 27, the Chadian government deployed troops to the Borkou Valley and launched attacks against a population of nomadic Fulanis who are governed by a jirga, or collective of elders, in the area.

Cpl. John W. Yates Jr., 26, of Ohio, is the first American killed in the Borkou Valley, as Human Rights Watch (HRW) has documented since 2017. In that time, rebel fighters have been ambushed, shot, set on fire, and shelled by government forces.

HRW has documented some instances in which government forces might have been responsible for the killings of civilians, including the December 2017 killing of 10 civilians in Borkou — the first mass killing of civilians that was known to have taken place since the signing of a peace agreement two months earlier.

The United States does not appear to have been involved in either the killing of the civilians or the January 2018 U.S. attack in the region that reportedly killed at least 20 people.

However, the United States has provided military and logistical support to Chad’s security forces in the Borkou Valley — including intelligence, equipment, and military training — since at least 2016. That support is ongoing, and some American personnel remain in the region.

As first documented by ICRG, this assistance is likely to help Chad avoid accountability for this latest killing in the Borkou Valley. U.S. involvement with Chad’s military operations in the region offers some protection to Chadian government forces.

Moreover, the United States has

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PDF Maker is a professional application designed to allow you to print from any application in PDF format.
You can edit PDF file after print. Add or remove pages, text, any images into that PDF file.
PDF Maker Description:
PDF Maker is a professional application designed to allow you to print from any application in PDF format. You can edit PDF file after print. Add or remove pages, text, any images into that PDF file.

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The judge will then have to decide whether the employee proved by a preponderance of the evidence that the employer’s reason is pretext for intentional retaliation. (The employee may find a third way: proving that the employer was motivated by the prohibited reason to retaliate against the employee, even if this improper motive was not the sole motivation behind the decision to terminate the employee. But in most retaliation cases involving conduct of the employer, the employee is trying to show that the employer was motivated by retaliation even though the employer’s decision to terminate the employee was not influenced by the prohibited reason.)

Once the plaintiff has persuaded the court that she has established her prima facie case and has proven by a preponderance of the evidence that the employer’s reason for termination is pretext for retaliation, she must still prove that she suffered an adverse employment action.

Determining What constitutes an Adverse Employment Action
The next step is to determine whether the plaintiff was subjected to an adverse employment action

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