Maybe it's just how such briefs are written but this thing doesn't seem to lay out evidence or argument that she should have been promoted and bonused. Nor does it trouble itself anticipating obvious benign explanations -- she wasn't good at her job, didn't work hard, etc. Doesn't she have to make some showing that her performance merited the compensation denied her?
It's going to be more difficult to prove performance when her performance reviews for the past few years are being challenged. At any rate, I'm sure merit will be discussed during the trial. IANAL but the brief is supposed to be a list of complaints, not a hagiography of the plaintiff.
