O'Donnell's filing reaffirms his claim that he was fired "without cause" from Bungie, and further alleges that Bungie has "a policy, pattern and practice of paying its employees accrued but unused vacation, paid time off, sabbatical time, and other benefits." The suit claims Ryan acknowledged and agreed to pay these benefits, yet to date has not done so. Because of this, O'Donnell is seeking twice the amount of the withheld wages, along with compensation to cover legal fees.
O'Donnell's filing also lists "separate grievances" against Ryan and Bungie, but said grievances are not being pursued in court at this time. However, O'Donnell wishes to reserve the right to append his original complaint with these separate grievances if they are not subject to arbitration.