TABLE 1: MATERIAL FALSE OR UNSUPPORTED STATEMENTS REQUIRING SWORN AFFIDAVIT OR DOCUMENTARY PROOF

#	Statement / Assertion	Responsible Parties	Contradicted By	Legal Basis	Demand
1	“Cox provided Mr. Coates with extensive accommodations.”	Azariah Workman, HR, Supervisor, Compliance Team	Direct systems evidence (Workday/HR logs); Third-party corroboration; Internal communications	42 U.S.C. § 12112(b)(5)(A)	Produce all records of “extensive” accommodations or sworn affidavit. If not, statement should be stricken and adverse inference applied.
2	“Mr. Coates refused to return to work.”	Azariah Workman, Supervisor, HR, Legal Counsel	Direct systems evidence (STD claim records, HR logs); Third-party corroboration; Internal communications	29 C.F.R. § 825.311(c)	Produce documentation of refusal or sworn affidavit. If not, statement should be stricken and adverse inference applied.
3	“Cox was unaware of any disability claim or need for accommodation prior to disciplinary action.”	Azariah Workman, HR, Supervisor, Payroll	Direct systems evidence (notification logs, HRIS entries); Third-party corroboration; Internal communications	42 U.S.C. § 12112(b)(5)(A)	Produce proof of lack of notice or sworn affidavit. If not, statement should be stricken and adverse inference applied.
4	“No medical documentation was ever provided to support Mr. Coates’ absences.”	HR, Azariah Workman, Benefits Team	Direct systems evidence (uploaded docs, HRIS, claim files); Third-party corroboration; Internal communications	29 C.F.R. § 825.302(c)	Produce documentation or sworn affidavit. If not, statement should be stricken and adverse inference applied.
5	“Absences in June were unexcused and subject to corrective action.”	Azariah Workman, Supervisor, HR	Direct systems evidence (approved leave logs, STD claim data); Third-party corroboration; Payroll records	29 C.F.R. § 825.220(c)	Produce evidence of unexcused absence or sworn affidavit. If not, statement should be stricken and adverse inference applied.
6	“Cox fully cooperated with all disability claims and requests.”	HR, Azariah Workman, Compliance, Benefits Team	Direct systems evidence (response logs, claim files); Third-party corroboration; Internal communications	29 C.F.R. § 1630.2(o)(3)	Produce documentation of cooperation or sworn affidavit. If not, statement should be stricken and adverse inference applied.
7	“No documentation was ever provided to Cox.”	HR, Azariah Workman, Benefits Team, Supervisor	Direct systems evidence (uploaded files, claim records); Third-party corroboration; Internal communications	42 U.S.C. § 12112(b)(5)(A)	Produce documentation or sworn affidavit. If not, statement should be stricken and adverse inference applied.
8	“Return-to-work date was not communicated.”	Supervisor, HR, Azariah Workman	Direct systems evidence (claim closure, RTW notices); Third-party corroboration; Internal communications	29 C.F.R. § 1630.2(o)(3)	Produce evidence of lack of notice or sworn affidavit. If not, statement should be stricken and adverse inference applied.