A female customer services manager received a favorable performance appraisal in February. In recognition of her good work, she received a bonus in April and was given an expenses-paid trip to Hawaii in May. Upon returning from the trip, she was discharged because she did not "fit in" and was replaced by a male. She was not charged with violating any rules or engaging in any misconduct during her employment. In ad- dition to suing for sex discrimination, she also filed claims of negligence and fraudulent mis- representation based on the performance appraisals that failed to inform her of any problems with her performance. Was the employer negli- gent in how it conducted its performance appraisals? Did it engage in fraudulent misrep- resentation? (Mann v. The J.E. Baker Co., 733 F. Supp. 885 (M.D. Pa. 1990))