did not address the fraudulent billing scheme, the
court found the jury could have reasonably concluded the
reference to "illegal activity" in Paolella's December 30,
1993 letter was part of his protests to BFI. Because BFI
terminated Paolella less than a month after receiving the
letter, the court concluded that causation was adequately
proven.

With respect to the motion for a new trial, the court
rejected the argument that its charge improperly instructed
the jury on the issue of reliance. In particular, BFI claimed
the charge allowed the jury to infer that BFI's customers
relied on the alleged misrepresentations, despite the
absence of any direct testimony from BFI's customers.
According to BFI, this relieved Paolella of his burden of
proving reliance, and placed the onus on BFI to disprove
that its customers relied on the alleged misrepresentations.
The court disagreed, holding the charge instructedCourt again took up the public
policy exception in Pressman. In that case, plaintiff
Pressman discovered that his superior, Pensak, was serving
as a technical adviser to a medical imaging technology
company, a position Pressman feared created a conflict of
interest. Pressman alleged that, after confronting his
superior, Pensak engaged in a retaliatory campaign to have
him fired. Defendant DuPont contended that the
employment-at-will doctrine barred Pressman's suit. While

                                10
the court's analysis focused primarily on the applicability of
the covenant of good faith and fair dealing set forth in
Merrill, it also examined the public policy exception to the
at-will doctrine, but concluded that Pressman's claim did
not satisfy