[brief] Defendant/Appellants [...] (“the Township”), [...]  (“[...]”), [...] (“[...]”), [...] (“[...]”), and [...] (“[...]”) (collectively, “Appellants”) respectfully submit this Reply Brief in connection with this appeal.  Plaintiff/Respondent’s (“Respondent”) Brief demonstrates a fundamental misreading of Appellants’ Brief-in-Chief.  To be clear, Appellants do not contend that Respondent did not plead disability discrimination.  Appellants contend that Respondent’s trial testimony materially deviated by testifying that the taking away of her Municipal Alliance Grant (hereinafter “the Grant”) salary was due to disability discrimination and/or retaliation for Respondent retaining legal counsel in January 2018.  Respondent’s testimony at trial in this regard constitutes a material deviation that rigorous cross-examination could not remedy, and which resulted in significant prejudice to Appellants’ ability to establish a coherent factual timeline to the jury.  This surprise testimony also created a misleading factual narrative and timeline for the jury, which had the effect of bolstering the credibility of otherwise flimsy allegations of disability discrimination and retaliation.  Respondent’s surprise testimony fostered a misleading narrative to the jury, which resulted in a verdict that stands against the weight of the evidence.  From commencement of this action until she testified at trial, Respondent claimed consistently that the Township took away her Grant salary based on religious discrimination.  Yet suddenly, at trial, Respondent sought to tie her allegations of disability discrimination and retaliation to the Township’s decision to stop the Grant salary.  Respondent’s cross-examination testimony established that she first notified the Township about her anxiety disability by submitting her initial Family Medical Leave Act (“FMLA”) paperwork in February 2018.  4T at 180:19-25—182:1-16.  Based on the undisputed chronology of events, the jury could not reasonably conclude that the Township knew Respondent had an anxiety disability prior to February 2018, over a month after the Grant salary was stopped, or retaliated against Respondent for retaining legal counsel.  Another misleading narrative was fashioned in Respondent’s trial counsel’s summative comments to the jury.  More specifically, Respondent’s trial counsel connected the decision to stop the Grant salary to disability discrimination and retaliation.  5T, 73:22-74:5.  Trial counsel’s summative comments reiterated Respondent’s surprise testimony and reinforced in the jury’s collective mind the misleading narrative that Respondent suffered direct economic harm due to disability discrimination and retaliation.  Without linking the Grant salary decision to disability discrimination and retaliation, Respondent does not have any evidence of economic harm.  Thus, the jury’s award of compensatory and punitive damages does not square with the weight of evidence presented at trial.  Lastly, Respondent’s counsel argues erroneously that Appellants waived the weight of the evidence issue with respect to her retaliation claim.  Appellants’ Brief-in-chief at Legal Argument, Points III and VI, discuss Respondent’s claims for disability discrimination and retaliation in the context of trial testimony and trial counsel’s summative comments, both of which had the prejudicial effect of misleading the jury based on Respondent’s surprise trial testimony.  Accordingly, the trial court’s ruling should be reversed, this matter should be remanded for a new trial, and this appeal should be granted for the reasons set forth in Appellants’ Brief-in-chief and further supported herewith.