In Romano v. Rockwell International, Inc., 14 Cal. 4th 479, 495, 59 Cal. Rptr. 2d 20, 926 P.2d 1114, 1124 (1996), the Supreme Court of California concluded that the statute of limitations commences to run under FEHA (FEHA is the California Fair Employment and Housing Act, which the appellant in Rockwell alleged the employer violated when he was terminated. 14 Cal. 4th at 491-92, 926 P.2d at 1121.) on the date of actual termination. In reaching that conclusion, the California Supreme Court determined that the usual and customary meaning of the term "discharge," in the employment context, is to terminate. Id. at 493, 926 P.2d at 1122. This definition, the court said, "is consistent with the plain meaning of the statutory language." Id. Additionally, the court identified several policy reasons for reaching the above conclusion: Determining the limitations period does not begin to run has the benefit of simplicity, in that the date of actual termination in most cases is subject to little dispute, whereas the notification frequently is oral and may be conditional or equivocal. Id. at 494, 926 P.2d at 1123. Holding that the statute of limitations begins to run from the time of notification of termination would promote premature and potentially destructive claims, requiring employees to seek a remedy for harm that had not yet occurred. Id. If employees are required to file claims once they receive notice of termination, that would reduce any chance of conciliation between the parties. Id. Courts would be required to prematurely adjudicate claims. Id. at 495, 926 P.2d at 1123. The court found further support for the position that the limitations period does not begin to run until the date of actual termination in other jurisdictions. Id. at 494-95, 926 P.2d at 1122-124.