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During this tirade, which was witnessed by Rick Snyder, Jessica Snyder’s husband, among others, Mr. Noga allegedly became physically aggressive, at one point grabbing Mark’s arm, and called him a “faggot”. One week later, Mark was notified that he was being placed under investigation. It’s alleged that the investigation was run entirely by Mr. Noga, not HR, which typically has always been responsible for employee investigations in the past. It’s alleged that Mark was never told explicitly what the charges against him were or who made them, although through conversations with Ms. Snyder he came to understand that he had been accused by two subordinates, Nick Batten and Adam Berger, of exceeding his Letter of Authority, failing to secure reinsurance on certain accounts, and submitting improper expenses. On December 27, 2021, Ms. Snyder insisted that Mr. Noga cease all involvement with the investigation, and appointed Sam Waters, Assistant General Counsel, to serve as the point person for Faegre Drinker, the outside law firm Mr. Noga had hired to conduct the investigation earlier that month. At that point, Mr. Noga and Nick Klinefeldt, the Faegre Drinker attorney investigating Mark, went to the board behind Ms. Snyder’s back and claimed that she had been attempting to interfere with the investigation. Based on this information, the board decided to recuse Ms. Snyder, who was not allowed to participate further in the investigation, despite having critical evidence that would have allegedly exonerated Mark from several of the charges against him. Mark eventually filed a formal complaint against Mr. Noga in mid-January 2022, first through the company’s anonymous hotline and subsequently in writing. His complaint was explicit about Mr. Noga’s bias against him because of his sexual orientation and detailed the homophobic epithets Mr. Noga had made both at the Des Moines Country Club and at the Flemings dinner. The company ultimately terminated Mark based on the charges brought against him. As a result of his termination, Mark has suffered significant lost income, including the denial of a six-figure bonus payment which was due just weeks after his termination. Andy Noga’s conduct has also caused Mark to suffer emotional distress, humiliation, loss of enjoyment in life, inconvenience, and other pecuniary and non-pecuniary losses, as well as attorneys’ fees and costs. Mark now seeks punitive damages due to Mr. Noga’s conduct throughout the entire ordeal.